Senate Hearing, 113TH Congress - The Consumer Financial Protection Bureau's Semi-Annual Report To Congress

THE CONSUMER FINANCIAL PROTECTION BUREAUS
SEMI-ANNUAL REPORT TO CONGRESS
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S. HRG. 11316
THE CONSUMER FINANCIAL PROTECTION

BUREAUS
SEMI-ANNUAL
REPORT TO CONGRESS
HEARING
BEFORE THE
COMMITTEE ON
BANKING, HOUSING, AND URBAN AFFAIRS
UNITED STATES SENATE
ONE HUNDRED THIRTEENTH CONGRESS
FIRST SESSION
ON
A REVIEW OF THE CFPB SEMI-ANNUAL REPORT TO CONGRESS
APRIL 23, 2013
Printed for the use of the Committee on Banking, Housing, and Urban Affairs
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S. HRG. 11316
THE CONSUMER FINANCIAL PROTECTION

BUREAUS SEMI-ANNUAL REPORT TO CONGRESS
HEARING
BEFORE THE
COMMITTEE ON
BANKING, HOUSING, AND URBAN AFFAIRS
UNITED STATES SENATE
ONE HUNDRED THIRTEENTH CONGRESS
FIRST SESSION
ON
A REVIEW OF THE CFPB SEMI-ANNUAL REPORT TO CONGRESS
APRIL 23, 2013
Printed for the use of the Committee on Banking, Housing, and Urban Affairs
(
Available at: http: //www.fdsys.gov /
U.S. GOVERNMENT PRINTING OFFICE

WASHINGTON
80865 PDF
2013
For sale by the Superintendent of Documents, U.S. Government Printing Office

Internet: bookstore.gpo.gov Phone: toll free (866) 5121800; DC area (202) 5121800
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COMMITTEE ON BANKING, HOUSING, AND URBAN AFFAIRS

TIM JOHNSON, South Dakota, Chairman
JACK REED, Rhode Island
MIKE CRAPO, Idaho
CHARLES E. SCHUMER, New York
RICHARD C. SHELBY, Alabama
ROBERT MENENDEZ, New Jersey
BOB CORKER, Tennessee
SHERROD BROWN, Ohio
DAVID VITTER, Louisiana
JON TESTER, Montana
MIKE JOHANNS, Nebraska
MARK R. WARNER, Virginia
PATRICK J. TOOMEY, Pennsylvania
JEFF MERKLEY, Oregon
MARK KIRK, Illinois
KAY HAGAN, North Carolina
JERRY MORAN, Kansas
JOE MANCHIN III, West Virginia
TOM COBURN, Oklahoma
ELIZABETH WARREN, Massachusetts
DEAN HELLER, Nevada
HEIDI HEITKAMP, North Dakota
CHARLES YI, Staff Director
GREGG RICHARD, Republican Staff Director
LAURA SWANSON, Deputy Staff Director
JEANETTE QUICK, Counsel
GLEN SEARS, Deputy Policy Director
PHIL RUDD, Legislative Assistant
JELENA MCWILLIAMS, Republican Senior Counsel
GREG DEAN, Republican Counsel
DAWN RATLIFF, Chief Clerk
KELLY WISMER, Hearing Clerk
SHELVIN SIMMONS, IT Director
JIM CROWELL, Editor
(II)
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C O N T E N T S
TUESDAY, APRIL 23, 2013
Page
Opening statement of Chairman Johnson .............................................................

Opening statements, comments, or prepared statements of:
Senator Crapo ...................................................................................................
1
2
WITNESS
Richard Cordray, Director, Consumer Financial Protection Bureau ...................
Prepared statement ..........................................................................................
Responses to written questions of:
Senator Crapo ............................................................................................
Senator Menendez .....................................................................................
Senator Hagan ...........................................................................................
Senator Moran ...........................................................................................
Senator Coburn .........................................................................................
ADDITIONAL MATERIAL SUPPLIED
FOR THE
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32
33
385
390
392
396
RECORD
Semi-Annual Report of the Consumer Financial Protection Bureau ..................
408
(III)
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THE CONSUMER FINANCIAL PROTECTION BUREAUS SEMI-ANNUAL REPORT TO CONGRESS

TUESDAY, APRIL 23, 2013
U.S. SENATE,
URBAN AFFAIRS,
Washington, DC.
The Committee met at 10:03 a.m., in room SD538, Dirksen Senate Office Building, Hon. Tim Johnson, Chairman of the Committee, presiding.
COMMITTEE
ON
BANKING, HOUSING,
AND
OPENING STATEMENT OF CHAIRMAN TIM JOHNSON
Chairman JOHNSON. Good morning. I call this hearing to order.

We have reviewed the CFPBs Semi-Annual Report and are here
today to conduct regular oversight of the CFPB. This includes making sure that the agency continues to fulfill its mission of protecting consumers and empowering them to make responsible financial decisions, promoting fair competition in industry, and ensuring full access to financial services for all Americans.
Director Cordray, welcome back to the Committee. I know you
share my commitment to transparency and accountability. In fact,
this is the 32nd time that a CFPB official has appeared before Congress in just over 2 years and your 13th appearance. Rightly so,
your agencys outreach and engagement with both consumers and
industry representatives has been widely praised.
The CFPB has made significant progress in protecting consumers, including students, servicemembers, and older Americans.
For example, the CFPB has developed a number of tools related to
student lending, including the Financial Aid Shopping Sheet, that
will help students make the best choices as they pursue their
dreams.
And since the CFPB opened its doors, it has obtained $425 million of consumer refunds. That is $425 million back into the hands
of harmed consumers and back into the economy.
Earlier this year, the CFPB finalized rules to strengthen mortgage standards. This includes the Ability to Repay provision, which
requires lenders to make a good-faith effort to determine whether
a borrower can make his or her payments. These rules have been
generally well received by consumer and industry groups alike, and
I applaud the care the CFPB undertook in writing these rules.
However, we must ensure that these rules do not have adverse impacts on lending in underserved areas, including rural areas. I look
forward to hearing from Director Cordray on how this rule will im(1)
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pact rural lending, which is an important issue for many in South
Dakota.
Finally, Director Cordray, you have made comments about reducing regulatory burden on community banks and credit unions. I
continue to be interested in your plans to make sure that rules
strike the right balance, protecting consumers while addressing legitimate concerns smaller institutions may have.
You have proven day in and day out that you are well qualified
for your position. Even my colleagues across the aisle concede this
point. I hope we can provide the market the certainty it needs and
consumers the cop on the beat they deserve by confirming you
quickly. Thank you for your service, and I look forward to our ongoing work with you.
With that, I turn to Ranking Member Crapo.
STATEMENT OF SENATOR MIKE CRAPO
Senator CRAPO. Thank you, Mr. Chairman, and thank you, Mr.
Cordray, for being here with us today. I appreciate it.
Mr. Chairman, this semi-annual briefing by the Consumer Financial Protection Bureau is very important to us to gain insight
into what the agency is doing. As I have consistently stated in past
hearings, we still have concerns with the structural nature of the
agency. We continue to seek a change from the sole directorship to
a board-like structure. It is also essential that the agency be a part
of the appropriations process. And, finally, we believe that the prudential banking regulators should have a formal input into the Bureaus action where those actions affect safety and soundness.
And with regard to the Presidents recess appointment to the
CFPB last year, my opinion has not changed. I continue to believe
the recess appointment was unconstitutional.
Recently, agency officials have pointed out that they have testified more than 30 times before Congress in the past few years. And
while this does give Congress an opportunity to hear directly from
agency officials and is appreciated, it does not necessarily facilitate
the in-depth discussion of the specific issues and concerns that we
need.
Just last week, Bloomberg ran a lengthy article citing that the
CFPB has allocated more than $20 million for collecting and tracking customer credit card and spending habits for more than 10 million Americans. The size of this data collection and the amount of
money being spent by the agency are a cause of concern for me
and should be for those Americans whose credit cards, checking accounts, and other financial data are being sent monthly to the
CFPB.
Last month, I specifically asked the agency about this data collection, but the responses I received downplayed the nature and extent of it.
For example, I asked how many consumer accounts the CFPB is
monitoring, and the agency declined to provide that information.
Now we learn from the press that it is 10 million accounts, and
perhaps even more.
This lack of candor and transparency of what the agency is doing
and how it intends to use this personal financial data is troubling.
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The Bureau was founded with a mission to watch out for American
consumers, not to watch them.
Given that the CFPBs Inspector General has already identified
data security issues at the Bureau, how can the consumer be assured that this information is indeed safe?
With regard to its regulatory role, in the past 2 years the Bureau
has issued numerous new rulemakings, resulting in significant cumulative burden for affected institutions, especially our small and
community banks that often have just a handful of employees.
In January alone, the Bureau finalized over 2,500 pages of new
rules relating to mortgages through seven different rulemakings. I
am concerned that, without strong cost/benefit analysis and input
from small business panels in crafting rules, even well-intentioned
rules could make consumer credit more expensive and less affordable.
That is why at two separate hearings last year I encouraged the
CFPB to conduct a small business panel on the proposed qualified
mortgage proposal to try to minimize unintended consequences.
Many community bankers now warn that, despite limited QM exemptions for smaller institutions, they will no longer offer any
mortgages outside the QM criteria, which will restrict their ability
to meet the mortgage needs of the communities they serve.
Another issue concerning the agency has been identified by the
agencys own ombudsman who recommended the CFPB needed to
review and clarify the role of enforcement attorneys who attend supervisory exams. I look forward to hearing from you, Mr. Cordray,
about how you plan to address the community bank concerns with
the QM rules and how the CFPB is implementing the overall ombudsmans recommendations.
Specifically, I would like to hear how the Bureau is handling the
examination concern raised by the ombudsman as well as whether
the Bureau is concerned about the effect that the sheer presence
of the enforcement attorneys may have on the integrity of the examination process.
I firmly believe that if the structure of the agency were changed,
then it would become more open and transparent, and many of
these issues would not need to be raised by Members of Congress.
It is my hope that the Congress will move quickly to address and
pass these reforms so that the Bureau can do what it was designed
to do, and that is, to protect the American consumer.
Thank you, Mr. Chairman.
Chairman JOHNSON. Thank you, Senator Crapo.
Are there any other Members who wish to make a brief opening
statement?
[No response.]
Chairman JOHNSON. I want to remind my colleagues that the
record will be open for the next 7 days for opening statements and
any other materials you would like to submit.
Mr. Richard Cordray is Director of the Consumer Financial Protection Bureau. Welcome back to the Committee, Director Cordray.
You may begin your testimony.
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STATEMENT OF RICHARD CORDRAY, DIRECTOR, CONSUMER
FINANCIAL PROTECTION BUREAU
Mr. CORDRAY. Thank you, Mr. Chairman, Ranking Member

Crapo, and Members of the Committee. Thank you for inviting me
to testify today about the Semi-Annual Report of the Consumer Financial Protection Bureau. My colleagues and I are always happy
to testify before the Congress. Ranking Member, I would hope to
have a chance to address each of the issues you raised in turn. If
that requires several rounds of questioning, I am happy to do it.
I think there are good answers to all of those issues that you
raised.
Born out of the worst financial crisis since the Great Depression,
the Consumer Bureau is the Nations first Federal agency whose
sole focus is protecting consumers in the financial marketplace. We
are dedicated to improving the lives of everyday Americans and to
restoring trust in consumer financial markets. The Semi-Annual
Report we are discussing today embodies our work over the last 6
months of 2012.
The report illustrates the ways we are using the tools Congress
has provided us to empower consumers and promote a fair, transparent, and competitive marketplace for consumer finance. We
have taken steps to improve the workings of marketsparticularly
those in which consumers cannot choose their financial service providers.
One such market is debt collection. Concerned about systemwide
problems that pose risks to consumers, we gained authority at the
beginning of the year to supervise debt collectors. The debt collectors covered by our supervisory authority account for over 60 percent of the industrys annual receipts in that market. Bad actors
in this market are a detriment to consumers and to every debt collector that operates lawfully.
We also expanded our supervision program to include the larger
credit reporting companies. Credit reports have a profound impact
on peoples lives. Previously, these companies were not subject to
any Federal supervision, and consumers often struggled to get errors resolved. In addition to our new supervision program, we
began handling consumer credit reporting issues, all of which will
open a clear window into the actual operations of these companies.
As a result, the Bureau can now evaluate whether Federal consumer laws are being followed throughout the process, from credit
origination to debt collection. By identifying problems and rooting
them out early, we are working to try to minimize consumer harm.
Our report also encompasses the Bureaus first enforcement actions, which were against credit card companies that deceived and
misled consumers. In some cases, the companies targeted economically vulnerable consumers with low credit scores and low credit
limits. We were able to secure $425 million in relief for 6 million
consumers, and we also imposed penalties on the companies to
deter such activity in the future. These actions will serve as a
warning signal for anyone who seeks to profit by deceiving or misleading consumers.
In the second half of 2012, we also tackled issues in the market
for private student loan debt, which currently totals about $150 billion outstanding. Our studies detailed the struggles students and
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recent graduates are experiencing in that market. Together with
Education Secretary Arne Duncan, we made recommendations to
Congress on commonsense reforms to ensure that the risky underwriting practices of the past are not repeated.
The work I am discussing here today is merely a snapshot of our
efforts on behalf of consumers. We also are addressing consumer
complaints on a growing number of financial products and services,
totaling more than 130,000 to date. We have adopted comprehensive new mortgage regulations banning irresponsible lending practices that helped bring about the recent financial crisis. Our Ability-to-Repay rule, also known as the Qualified Mortgage rule, follows the simple principle that lenders should offer consumers mortgages they can actually afford to pay back. We have actively conducted outreach on various issues to older Americans, students,
servicemembers, and others, and what we heard from them has
guided the direction of our work.
Each day, we take another step in pursuit of our vision to create
a consumer financial marketplace where customers can see prices
and risks up front and easily make product comparisons; in which
no one can build a business model around unlawful practices; and
that works well for individual consumers, responsible businesses,
and the economy as a whole. We will continue to persist in this
work, and we appreciate your oversight. As always, I will be glad
to answer your questions.
Thank you.
Chairman JOHNSON. Thank you very much for your testimony.
As we begin questions, I will ask the clerk to put 5 minutes on
the clock for each Member.
Director Cordray, in both the CFPBs servicing rule and QM rule,
you provide allowances for rural areas and community banks. I
have heard from several constituents that the threshold for rural
lending will limit lending by small banks and credit unions. How
will those rules impact lending in rural or underserved areas? And
what have you done to address these concerns? More specifically,
why did you select a 5,000-loan threshold for defining small
servicers?
Mr. CORDRAY. Thank you, Mr. Chairman. One of the objectives
Congress set for us and requires us to do with every new regulation, in addition to assessing costs and benefits, is to assess impacts on smaller providers and also rural areas. This is something
that we paid close attention to with the Qualified Mortgage rule
and the servicing rule, as you mentioned.
That led us to write provisions into the rule that are specific and
special to smaller providers and community banks that would recognize the role they play in some of the more challenging areas,
such as rural areas and underserved areas, to underwrite loans.
We provided a special provision for smaller institutions that has
been reproposed, and will be finalized shortly, to recognize that if
they are holding loans in portfolio and they are operating according
to their traditional underwriting models, those are good loans. This
is good lending, and it is sound lending that we want to encourage.
We took the original proposal that was produced by the Federal
Reserve, which had a narrow definition of rural, and would have
covered about 2 percent of the population, and we expanded that
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tremendously to almost 10 percent of the population. We have
heard further comments since then to suggest that we could have
written that even bigger. That is something that we are looking at
and thinking about as we get more comments, even after the rule
has been finalized.
On the servicing rule, we originally proposed an exemption for
smaller servicers, many of whom have very few foreclosures and a
high-touch customer model, which is something we want to encourage, frankly, as a model to the larger servicers. We originally proposed an exemption for those that service 1,000 loans or fewer.
After receiving comments from smaller providersand we had
SBREFA, a small business review panel, as Senator Crapo mentioned, on that rulewe ended up expanding that to those who
service up to 5,000 mortgages. We estimate that this covers about
98 percent of the smaller providers. They are exempt from significant portions of that rule.
We are trying to be careful and sensitive to not having a onesize-fits-all approach and to recognizing that smaller lenders, particularly in rural areas, are of interest to Congress, they are of interest to the market, and they are of interest to consumers.
Chairman JOHNSON. Director Cordray, as you know, outstanding
student loan debt now exceeds $1 trillion. The CFPB recently
asked for suggestions from the public on how to make student loan
repayment more affordable. What does the Bureau plan to do next
with regard to student lending? And what do you view as the biggest risks in this market?
Mr. CORDRAY. Thank you for the question. It has been an active
area for the Bureau and for our Ombudsman of Students, which is
a position that Congress created in the Bureau. There are several
things. I will try to move through them quickly and am happy to
have you follow up as you wish.
First of all, for those who are undertaking the decision whether
to go to college and how to pay for higher education now, we have
created new tools, such as the Financial Aid Shopping Sheet, which
you mentioned. That has all been folded into a broader Paying for
College module that is on our Web site. We are rolling this out to
guidance counselors, teachers, parents, and young people themselves across the country right now as they are beginning to make
these financial decisions for the coming school year.
Second, we have just put out a rule to be able to supervise student loan servicers, many of whom may be suffering some of the
same problems that mortgage servicers had suffered as we hear
from consumers around the country. We will be actively and directly examining them to make sure they are complying with the
law.
On the proposal that you mentioned that we put out to gather
thoughts and ideas from the public about what could be done about
the existing student loan problemwhich is burdening the economy, as the Federal Reserve has recognized in the past month, and
is slowing down housing purchases and care purchases and other
thingswe have received a tremendous amount of interest. We had
over 28,000 comments submitted on that proposal, which we are
going through. We are working with a number of other entities, including Treasury and other parts of the Government and, of course,
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the Department of Education to see what can be done to help address this problem. It is a work in progress.
Chairman JOHNSON. Senator Crapo.
Senator CRAPO. Thank you, Mr. Chairman.
I want to talk, first of all, Mr. Cordray, about the data collection
issue that I raised in my opening statement. As I indicated, it appears that the agency is collecting data on at least 10 million
Americans. In the Gramm-Leach-Bliley Act, Congress allowed consumers to opt out of having their personal consumer financial information shared with third parties. Shouldnt consumers be given the
opportunity to opt out from having their financial information
being shared with the Federal Government as a part of the CFPBs
data collection efforts?
Mr. CORDRAY. Thank you for the question, Ranking Member
Crapo. The story you adverted to in Bloomberg, which I also read,
I think misunderstood a number of things about what the Bureau
is doing, and I am happy to have the chance to clear that up.
Senator CRAPO. Please do.
Mr. CORDRAY. First of all, big data is the cutting edge of analysis
and research right now in every field that involves analytics in this
country. IBM, the big banks, and every company that deals with
the public is gathering and crunching as much data as they can.
I have seen figures that show that 90 percent of the data that exists in the world was created in the last 2 years. This is happening
in the private sector. It is the way of the world. The big banks
know more about you than you know about yourself, and me, too,
as a consumer. The notion that the regulators would not keep up
with them in trying to do our job of overseeing them I think would
be quite misguided.
Now, what are we doing in terms of gathering data? First of all,
I want to stress that the data we are talking about are
anonymized. It is not personal identifiable information about individuals, so the notion that we are tracking individual consumers or
somehow invading their privacy I think, is quite wrong.
Many of the data sources that we are accessing are commercial
data sources, of which many entities are buying and selling the
data in order to be able to analyze what it shows about the markets. For example, our credit card data comes from Argus, which
is a source that is used by a number of other regulators, as well
as by companies themselves. The National Mortgage Database that
we are putting together is all about having the data to be able to
do the things that Congress requires us to do and that you talk to
me about frequently. You want us to do careful cost-benefit analysis. We cannot do that without good data. And, frankly, for the
mortgage rules, we found that we need to develop a National Mortgage Database so that data is even better in the future.
Congress asked us to write reports. We have a report due later
this year on the CARD Act and what the effect of the CARD Act
has been. We cannot write a report like that and have it be meaningful and helpful to the Congress unless we can analyze the data
to be able to see what the actual consequences have been.
This is the work we are doing and it is important for us to have
data so that we can analyze it and we are not dependent on asking
the financial institutions what they think. That is not the proper
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role for a regulator. And, again, the data is typically anonymized.
It does not go to you or me in particular, but it goes to consumers
generally and is quite helpful and really essential to us to do our
work.
Senator CRAPO. Well, I appreciate that response. Let us talk
about the anonymity issue first. Again, my understanding from the
Bloomberg article is that the CFPB has let a number of different
contracts to different private sector entities to collect and store the
enormous amount of data that the agency is collecting. Even if the
data collected is not personally identifiable to the agency, isnt it
possible for the CFPB to hire contractors to dig into this data and
obtain personally identifiable information?
Mr. CORDRAY. I do not know if that would be possible or not,
Senator. I am not sure that it would be. It certainly is not what
we are doing and not what we are going to be doing. We have no
interest inhow did you phrase it?watching consumers. We do
have an interest in understanding how financial products and services are affecting consumers. We have an interest in being able to
do the kind of very meticulous cost-benefit analysis you want us to
do as we write rules so we can get them right. We have an interest
in making sure that the studies and reports Congress is asking us
to do to help inform your policy decisions, which is the law that we
follow, are on sound grounds and that we can see over time whether the objectives you are trying to achieve are being achieved. That
is the work that we are doing.
Senator CRAPO. Well, I understand your point about the fact that
collection of data is occurring at phenomenal rates in the private
sector. I and I think many Americans are concerned about that as
well. And the notion that the Government needs to keep up with
the big data trend is one that I understand your point in terms of
wanting to be able to regulate those in the private sector who are
themselves collecting this data, but it seems to me that there is a
huge issue here about whether the Federal Government should
now be getting in a big way into the kind of data collection that
you are talking about.
I see my time is up. I will come back to this in another round,
and we can discuss it further.
Mr. CORDRAY. I look forward to that. Thank you.
Chairman JOHNSON. Senator Merkley.
Senator MERKLEY. Thank you very much, Mr. Chair. And thank
you so much for your testimony and your leadership of the CFPB.
I wanted to first ask, following up on the data question, specifically about the complaints database. Can you just share a little bit
aboutfirst, I believe that there are no names attached to it, like
who complained about what, that it is anonymous, but that it gives
you kind of ait gives everyone a sense of what consumers are
most concerned about. If that is correct, can you confirm that it is
anonymous? And, second, what are the top three or four concerns
that you see coming out of that database?
Mr. CORDRAY. Thank you for the question, Senator. The database
of consumer complaints, which is something that I think people are
gradually getting used to, is analogous to what has been done for
40 years by the National Highway Traffic Safety Administration.
What they have done has led to tremendous improvements in auto
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safety, and the auto companies now embrace it, although they did
not at first. It is also analogous to what the Consumer Product
Safety Commission is doing to make sure that the public is aware
of hazards of lead in toys and other types of things that maybe we
were not aware of for 20 years, but are probably better off now to
know about and be able to protect our children.
Similarly, what we are doing is, as we receive complaints, we
scrub the complaints and remove any duplicates. We verify that
there is a customer relationship between the complainant and the
institution being complained about. We do anonymize that data. It
does not reveal personally identifiable information. That is something we are very careful about, we are required by law to be careful about it, but also I frankly think it would bring the agency into
disrepute if we were not careful about it.
There is a growing amount of information that that yields. I
think at this point our consumer complaint database, when we
broadened it a month ago, had 90,000 cumulative complaints. They
are added day by day now, so the number of complaints may be
closer to 100,000.
I will say this is nothing novel around the world. In the United
Kingdom, their Financial Services Authority has been publishing
complaint data about banks for years. In the most recent 6-month
period, they published 3.4 million complaints about the banks.
Senator MERKLEY. I am a little worried about running out of
time, so what are the three or four top issues, insights that have
come from the database?
Mr. CORDRAY. First of alland, frankly, your offices could probably tell us the same thing with the kind of inquiries you get from
constituentsthere is tremendous concern about mortgage servicing and a tremendous number of complaints and consumer harm
in that area.
Secondly, on credit card complaints, I would say what it has actually showed usthis is somewhat surprising to me because I remember before the CARD Act this was a very controversial area for
the publicthat the complaints are down, I believe. This is showing better work by the companies, more careful attention to what
the CARD Act now requires, and I think our report later this year
will show that there has been real progress made there.
An interesting one for us, and fairly new and too preliminary to
have much conclusions yet to draw, are credit reporting complaints.
People generally are not aware of how significant an effect on their
lives their credit reports have, but those that are have found a variety of errors. They are having trouble getting those errors corrected, and we are starting to hear about it as we started taking
those complaints earlier this year.
This is information that is illuminating to us as we go about
doing our work. We think, as a result, it is illuminating to companies about how they can better improve their processes. And I
think it is illuminating to the public, who has a right to know this
information and to make assessments accordingly. I think it is good
all around and we should have more information rather than less.
Senator MERKLEY. Thank you. And since you mentioned it, the
mortgage servicing is continuing to be an area of significant consumer concern, and certainly I still see that through our case
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workthe calls our case work team gets. Some of the issues that
have been raised in servicing are foreclosure mitigation discussions
to try to make sure there is clear communication and all options
have been pursued, and the dual track, which still exists to a degree. But any insights on the aspects of mortgage servicing that
are particularly still troubling to consumers?
Mr. CORDRAY. Senator, I think it is frustratingit is frustrating
to me, I am sure it is frustrating to you and your colleaguesthat
it is still the casemaybe less so and some servicers have clearly
improved and others have yet to improve. There are still some fundamental issuesblocking and tackling, lost paperwork, people not
answering the phone, not getting the single point of contact that
has been promised. But I would say that the dual tracking is a
great concern. The notion that somebody is working with you with
the left hand and trying to get your loan modified while with the
right hand, maybe unbeknownst to you, are proceeding to a foreclosure and undermining the work that you think you are accomplishing. That is very aggravating to people.
The new rules that we have devised that are going to go into effect in January are going to make a significant difference in this
respect, and they apply across the entire market, to both the
servicers that are banks and the servicers that are nonbanks. That
has never before been the case. We met face to face with the top
executives from all of the large servicers, the top several dozen
servicers, last year, to let them know this was coming. We also let
them know the importance of this and to take this seriously and
not to wait. And I would hope that over time your offices and our
Bureau will hear less about these kind of complaints, but right now
they remain very significant.
Senator MERKLEY. Thank you very much.
Chairman JOHNSON. Senator Johanns.
Senator JOHANNS. Thank you, Mr. Chairman.
Let me follow up on Senator Crapos questions about data collection. Where do you go to get the data?
Mr. CORDRAY. I would focus on three different areas: credit card
data, which is critical for us to have in order to do things like prepare the CARD Act study that Congress has required us to
produce
Senator JOHANNS. Right, but do you go to Visa or MasterCard?
Mr. CORDRAY. Typically, on the credit card dataand it is a different answer for different categories, and I am reading from notes
that my staff prepared forwe have been collecting this data
through Argus, a known collector of data. It is used by any number
of institutions and by other regulators, and so we are following
very well plowed ground in assessing that data.
Senator JOHANNS. So they go to Visa or MasterCard or whoever?
Mr. CORDRAY. Or issuers themselves might be like Wells Fargo
or Bank of America or JPMorgan Chase or any of those who issue
cards.
Senator JOHANNS. OK. You mentioned there are three. So there
are two others. Where else would you go to get the data?
Mr. CORDRAY. The second area, the National Mortgage Database
that we are going to be creating together with the FHFA is essential, because what we have found as we were writing our mortgage
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rules is that the mortgage data that is extant is not as good as it
should be. Loan origination data is often decoupled from loan performance data, and there are holes in the data, so that it is not
necessarily representative of the entire market. That made it somewhat challenging for us as went to write those rules, and we did
a pause on the QM rule where we went and got more datawe
were able to get more data from FHFA. They were very cooperative
and collaborative with us and helped us on that. Then we put out
for more comment because we were going to be using new data
that did not surface before, so that we made sure that the process
was full and complete.
Going forward, that data is being gathered over time in real time
on mortgages. This will provide a much more representative sample of what the mortgage market is doing so that we see the problems in real time, which we could not do very well over the last
decade, and it helped lead to the crisis.
Senator JOHANNS. And one more place you mentioned.
Mr. CORDRAY. The third category has to do with credit records,
and in that case, we have been buying the data from credit reporting agencies, as the Federal Reserve Bank of New York has done
for a number of years. They have used that data for a number of
years to publish their report, a quarterly report on household debit
and credit that is widely quoted.
Again, we are following their lead in terms of this is good data
on credit reporting. It is going to help us have the insights to help
protect consumers and understand whether laws are being followed
as well as what the effect on consumers is of different practices.
Senator JOHANNS. So individuals payment performance, whatever, is the basis upon which this mega data is created, obviously.
So somehow, some way, the Government is getting control of information about how people pay their mortgage or their credit card
bill or whatever.
Mr. CORDRAY. I think this is an important difference, and I want
to stress it. If by that you mean we are getting information about
whether Richard Cordray is paying his mortgage and when and
how, that is not the way the data works. What we are getting information about is consumers and how their mortgage performs
over time. But it is anonymized. I do not have access to data about
you or about myself. It is anonymized consumer data. But you have
to have data about consumers if you are going to understand what
is going on in the consumer marketplace. There is no two ways
about it. You all want us to write rules where we have careful assessment of costs and benefits. If we do not have data and information about what the impacts in these markets are, we cannot do
that. We cannot do our job. And I think you would be quite dissatisfied with us, and rightly so.
Senator JOHANNS. I am out of time already, Mr. Cordray, but
here is what I would say to you. To many people, this is going to
sound downright creepy, to be honest with you. It is. And I just
think people are going to be bothered by the fact that there is this
Federal agency that is collecting data on the behavior of people like
you and me and everybody else who is paying off a mortgage, who
is paying credit card bills every month. I think it is a very uncomfortable situation for your agency.
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Mr. CORDRAY. I think if people want to misunderstand that, that
it is somehow following them individually and somehow invading
their privacy and tracking into their personal lives, that is not
what it is. We have to have information about what is going on in
these markets. What goes on in the markets is an aggregate of consumer behavior, consumer performance, consumer harm, and consumer benefit. If you do not have any information to do this work,
then basically you are a know-nothing and you are not going to be
able to do the work well. And I think you would rightly be very
critical of us if we just operated based on speculation and did not
make an effort to ground our policy judgments in such information
as is widely available and widely used and anonymizedvery importantly, anonymized.
Chairman JOHNSON. Senator Reed.
Senator REED. Well, thank you very much, Mr. Chairman, and
thank you, Director Cordray.
Let me raise an issue that I think you and your colleagues that
are looking after our military are aware of, and that is, there are
military personnel who cannot immediately get on-post housing.
They apply. It might take months as the list reaches them. In the
meantime, they have entered into a rental contract, and in some
States there is a severe penalty for breaking the contract. There
are other States that I am aware of that actually have State laws
that say if you are going on post, then the landlord cannot impose
a penalty.
Can you comment on how you are trying to deal with this? Because for many military personnel this is a real serious issue.
Mr. CORDRAY. Thank you, Senator. I would say there are several
different housing issues for servicemembers, both active duty and
reservists, and their families, that we have encountered, as Holly
Petraeus, our Assistant Director for Servicemember Affairs, has
been around the country and talked to and brought back accounts
from folks on the bases.
One of the issues was the permanent change of station orders
problem that I know you are very familiar with and that we
worked with the Department of Defense and others, such as the
Department of Treasury, to address last year was to qualify that
as a hardship for the HAMP program.
What you are raising is another great example of how there can
be a general consumer problem, the issue of tenants who are renting and can be affected by some of these problems. A great example
is when Congress dealt with the fact that tenants can be ousted
from the place that they are living because the landlord is foreclosed upon even though the tenant may know nothing about that.
It comes without warning, and they find their belongings on the
street.
For the military, again, this particular instance can do with
change of station orders or it can do with, as you say, trying to improve your housing for lesser cost. If Congress is going to look at
that issue, we would be happy to supply the experience that we
have seen from around the country. That is, of course, a judgment
for you all to make, but I would say it is another outstanding example of how you can have general consumer issues, and then you
translate them into the military context. These still are general
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consumer issues, but they often are sharpened or aggravated by
the particular situation of servicemembers who often have limited
choice because they have to obey orders, they have to go where
they are told, and they have to be there when they are supposed
to be there.
Senator REED. Well, we would appreciate working with you. If it
requires legislation, I think my sense is that we support this on
both sides, because it has a huge impact on personnel. They could
move from expensive rental quarters to on-post housing, more convenient, et cetera. And as you point out also another dimension,
sometimes it is not just getting on-post housing. It is a complete
change of station, and they have to go, and yet they pay a penalty.
And we will do ourI would like to work with you on this.
Let me turn to another subject, and that is, looking at the recent
semi-annual report, I was disappointed to see your comments about
the confusion that persists around the process and requirements
for obtaining mortgage loan modifications. I do not have to tell you,
because we spent a few sessions under the leadership of Chairman
Johnson talking about this, the big deal, the modification deal, and
now we have found out just recently that even some of the people
who were owed checks, the checks bounced.
So can you generally comment about what you are seeing and
what you can do to help in this modification issue?
Mr. CORDRAY. I think most importantlyand as Congress directed us to dowe have adopted new rules that are pretty comprehensive for the mortgage servicing market. They will take effect
in January, and I think the companiesI know the companies are
already at work implementing them now. Frankly, they should
have come as no surprise. These problems have been surfaced and
publicized not for months but for years. They are pretty common
across the industry and yet they are galling because they affect individuals lead to bad results for individuals. They lead to people
losing their homes, which is the most precious thing that people
possess, and it upsets their personal finances tremendously, so I
think that our rules will make a big difference.
We are already also underway examining mortgage servicers onsite and looking at whether and how they are complying with the
law. Some of them are doing a decent job. Many of them have problems, and for many of them, it is going to require corrections and
compliance and perhaps enforcement actions as needed.
Right now, we are now in a position, as this new Bureau that
did not exist before, to examine the institutions directly, to ensure
that they are complying with the new regulationswhich went beyond what Congress required but was necessary to address the
scope of the problemsand to enforce the law as needed to bring
them into shape, which is long overdue.
Senator REED. Now, going forward, you are going to have a much
better process and procedure, but we have a whole category of
Americans that are still caught up in the old system.
Mr. CORDRAY. Yes.
Senator REED. Let me ask a question, nonrhetorical. You are not
involved with OCC and the Federal Reserve in this settlement that
proposed to modify mortgages and compensate people for illegal
foreclosures? Were you involved at all?
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Mr. CORDRAY. No, we were not involved. I will say that at the
time all of that began to unfold, I started as Attorney General of
Ohio, and we did see the problemsthe robo-signing and all the
rest. I then joined the Bureau, and we had a transition period
where we were not yet an independent agency.
Our role in this is a going-forward role. It is not so much a looking-backward role, but I want to stress, when I say going forward,
everybody who is caught up in this situation, as soon as our rules
take effect, are governed by those rules. It does not matter that the
mortgage was entered into 3 or 5 or 8 years ago. The examinations
that we are in the process right now are examining the problems
right now. The other processes that are looking back to things from
several years ago is a different issue. But for us, the present and
the future is very much the agenda Congress has given us, and we
are going to be aggressive about trying to fix these problems.
I also wanted to thank you for the efforts you and your colleagues have made on the changes in the Military Lending Act. I
know you and your staff have been inquiring of us how it is coming
to implement those. It is coming well. We are working with multiple agencies, including, of course, centrally the Department of Defense, and I think we will implement those changes in the law in
the manner in which Congress intended.
Senator REED. Thank you very much.
Chairman JOHNSON. Senator Shelby.
Senator SHELBY. Thank you.
Mr. Cordray, good morning.
Mr. CORDRAY. Good morning.
Senator SHELBY. The Financial Stability Oversight Council, of
which the CFPB Director is a member, was given broad authority
to eliminate market expectations that any American financial firm
is too big to fail. You are very familiar with this.
Do you agree that as a member of FSOC, the CFPB director has
a responsibility to contribute to these discussions and help identify
threats to our financial system?
Mr. CORDRAY. That is a responsibility Congress has given me by
law, yes.
Senator SHELBY. So you believe you have that responsibility?
Mr. CORDRAY. I believe I do, yes.
Senator SHELBY. Do you believe that all systemic risks have been
contained and too-big-to-fail expectations that large institutions
will not be allowed to fail have ended? Or still are there some
threats out there?
Mr. CORDRAY. Well, my perspective on this is sort of limited and
more recent. I was not here in Washington and not directly involved in the events of the financial crisis. I was the treasurer of
Ohio at the time overseeing billions of dollars in public finance.
What I will say is what is clear to me from my work on the FSOC
thus far. There is tremendous work in progress, tremendous strides
have been made, and I think the framework is both there and
being put in place more specifically to address those threats to the
system.
Senator SHELBY. Do you basically support limiting the size of
banks as proposed by Senator Brown and Senator Vitter?
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Mr. CORDRAY. I think that is a policy call for the Congress. My
job under the law is to examine those banks for compliance with
consumer protection laws, and that is what we are focused on
doing. Whatever structure Congress would impose or influence in
the banking industry, we will adapt to that and do our job. We do
have $4 trillion dollar banking institutions that are challenging institutions. They are in multiple product lines, and we are pretty
much continuous in our presence supervising them.
But I would say that we are focused on doing our work, and I
think those legislative debates will obviously proceed, and you all
will make your judgments, and we will follow them.
Senator SHELBY. Do you basically believe that we should and you
should as an insider eliminate systemic risk as much as possible?
Mr. CORDRAY. I think we should do our best to minimize systemic risk. I do not know that you can eliminate it entirely, but I
think you can certainly, by being conscious of it and being more
prepared. I think that minimizes the risk, and from there you do
the best you can.
I will say that the wisdom of Congress in the law of placing me
as a representative of my Bureau on the FSOC, which is, of course,
the body that could veto our regulations if they strongly disagreed
with them, I think it has been very helpful to me both in understanding the perspective of that body and in having the chance to
work together with my colleagues. This has helped me understand
their point of view and they can see and understand the work we
are trying to do that Congress has tasked us with.
Senator SHELBY. Last Congress, I asked the Inspectors General
of a number of financial regulators to review the economic analysis
performed by the agencies under their supervision. The IGs reported back that, to the extent economic analysis is performed, it
is often focused on compliance costs rather than looking at the effects the rules will have on economic growth and job creation.
Determining compliance costs is critically important. We know
that. But it is just one component of the overall economic impact.
Do you believe it is important for regulators to understand the
macroeconomic impact of rulemaking activities?
Mr. CORDRAY. I do, and for us that has been in particular understanding the effects on access to credit and the effects on smaller
providers and larger providers. But I would go back to my discussion with Senators Crapo and Johanns. We cannot have that understanding on data collection and we cannot do that work if we
do not have the information on which to make those judgments, so
I do think it is critical for us to do that, Senator, yes.
Senator SHELBY. Dodd-Frank expressly requires the CFPB to
evaluate the costs and benefits of any proposed rule. You are familiar with that.
Mr. CORDRAY. Yes.
Senator SHELBY. If your economic analysis determines that a
rules costs outweigh its benefits, do you think the rule should still
be implemented, rewritten, withdrawn, redebated, or what?
Mr. CORDRAY. My sense of why Congress tells us to do analysis
of things like benefits, costs, impacts on smaller providers, impacts
on access to credit, and impacts on rural areas, is because Congress
intends, and I think has made it very clear, that we should take
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into account our judgments about deciding whether to proceed with
a rule or how to write that rule. It may be that a rule in one form
would have negative impacts there, but if you modify it a bit, then
it improves. The specific provision is 1022 of Title 10 of DoddFrank, and it specifies how we are to go about this. We have been
very faithful to that. It does, again, require information and data
in order to do that work properly. I think that the dilemma we
might find is if Congress has required us to do a particular rule
and we found that the costs and benefits, you know, were troublesome, then we can try to write the rule somewhat differently, but
obviously within the confines that Congress gave us. Or we could
always come back and talk to you all about it. That would be a
troublesome area. But where we have discretion, the costs and benefits are something that I think should definitely guide our policy
judgments.
Senator SHELBY. But in addition to analysis, for which you need
data and everything, we understand that, to make a good judgment, you need objectivity of the whole situation, do you not?
Mr. CORDRAY. You need to try to have that. I try to have that.
I hope that we do. I think one way we can get there is by listening
closely and being very accessible to all viewpoints, to using the
processes that Congress gives us as much as Congress has done so,
do the analysis, and do the notice and comment rulemaking where
people have a lot of access to usin our case, where appropriate,
where the law requires to do the SBREFA panels, which we have
found useful to us. All of those thingsobviously the processes are
provided, I assumetry to improve our rulemaking so we do not
go off the rails and do something that is detrimental to the economy or detrimental to consumers. And I have no desire to do that.
I want to carry out the tasks Congress has given us to the best of
our ability. I want you all to feel, when you look and see what we
have done, that you can be proud of what we have done and that
our work reasonably reflects what your intentions were. And if it
does not, I know I am going to hear from you.
Senator SHELBY. Thank you.
Chairman JOHNSON. Senator Brown.
Senator BROWN. Thank you, Mr. Chairman.
Mr. Cordray, it is nice to see you again. Welcome back in front
of our Committee, your at-least-twice-a-year visit. We have talked
about many of these things that never in our history has someone
been in many ways held hostage a qualified nominee of the President because a significant number of Members of the Senate, pretty much all of one party, do not like the structure of the agency
or wish the agency did not exist. I guess this is the second time
in historyyou were the first time in history a year or so ago. Senator McConnell said the other day, if he had his way, we would not
have this agency at all.
I want to talk about accountability, though, because they lay this
all at the feet of the issue of accountability. Understanding that
there is an FSOC veto over what you do, understanding, unlike
most people in the agencies, that you come, you issue a report and
come to this Congress at least twice a year, versus if you went
through the normal Administrative Procedures Act, make that con-
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trast for me, your accountability as this agency is set up, as the
CFPB is set up, versus that kind of accountability that other similar agencies might have.
Mr. CORDRAY. Senator, I think we are all accountable in very
fundamental respects. I think we are all accountable to the Congress, which can, of course, always change the law and has provided the law that we are required to implement faithfully. We are
all subject to court oversight. If we adopt rules, there are specific
processes we have to follow, and the courts can look over our shoulder and make sure we did that. They can also review the rules for
substance. And, we are subject to oversight by the Congress directly as in hearings of this sort.
Now, in that regard, the Bureau is special. There were special
concerns about the Bureau, and it showed up in special structural
constraints on the Bureau.
Number one, we are unique among the Federal agencies in that
our rules can be subject to a veto by other agencies, even aside
from also potentially being reviewed and overturned, if appropriate,
by the courts.
We are subject to a GAO audit of our finances as opposed to, in
general, most agencies and departments, the GAO audit is of the
Federal Government as a whole, not specific to their finances.
We are subject to an independent audit annually of our operations. That is, again, not something that is done at other agencies.
I am happy to say that those audits have been clean audits to date
even as we are building up and trying to build the agency as well
as perform our duties.
We are subject, unlike the other banking agencies, to a hard
budget cap and then told that, if we need additional money, we can
come to Congress for an appropriation. So we are sort of quasi-appropriated as it is.
We are required to produce a semi-annual report and to testify,
therefore, twice a year in front of the Senate Banking Committee
and the House Financial Services Committee as an oversight on
that report.
I want the Senators not to underestimate yourselves. This is
meaningful oversight. When I sit here and have to answer your
questions, it is not just fun and games for me. I take it very seriously. I am accountable to you, and if I cannot answer your questions and respond to your concerns in a way that is persuasive to
you, then I have a problem and an issue, and it is a meaningful
issue for me.
There are many ways in which the Bureau is specifically constrained beyond other agencies. We accept that. We are doing our
best to do our work within that. And, frankly, I do not mind having
strong oversight. It helps me make sure that I can sleep at night
that we are, for the most part, I hope, doing the right things.
Senator BROWN. Thanks. I do not think too many of us thought
this was fun and games for you to come in front of these committees.
[Laughter.]
Senator BROWN. Not the first term or phrase that came to mind.
I want to follow up a moment in my last minute or so on Senator
Johnsons questions about the private student loan market. The re-
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cent report by the student loan ombudsman has been important.
My Subcommittee, as you know, held a hearing examining this
issue last year. How will your new supervision of large private student loan servicers address some of the concerns described in these
reports and these hearings?
Mr. CORDRAY. I think, first of all, it is a meaningful change, Senator, to have an agency that goes in and examines very specifically
for compliance with the law in an area. It means the institution
has to be on their toes, and it means we have direct access to the
information we need to assess whether the laws are being followed.
That already changes attention and heightens the consciousness,
and I believe changes behavior in these institutions and the examination function itself.
On the private student loans, as I said, have put in place the
mechanism to be able to now examine the student loan servicers,
the ones who are actually dealing with the outstanding student
loans and either getting the right information to people or not, either processing these loans properly or not. We hear a lot of complaints about that, so we will be aggressive about going in and
making sure that things are being handled correctly, or if they are
not, that they are put right.
The whole student loan problem is a problem that should be of
deep concern to this body. These are young people that we should
care a great deal about. They are the ones with ambition, aspiration, and are getting saddled with debt that they do not understand, often. They tell us later that they wish they had known the
difference between a private student loan and a Federal student
loan. This is holding them back, and it is making them unable to
rise and succeed and become leaders in our society, and it is a significant problem. We are going to be doing everything we can to address it at the Bureau.
Chairman JOHNSON. Senator Warren.
Senator WARREN. Thank you, Mr. Chairman. Thank you, Ranking Member.
I just want to say this is my first full day back in the U.S. Senate since the attacks on Boston, and that many here, many of my
colleagues, the staff, members of the press, members of the public,
have held Boston in your prayers for the last week. And on behalf
of myself, on behalf of the people of the city of Boston, I want to
say thank you very much. You know, it has been a hard week, but
the people of Boston are fighters, and we are strong, and we will
get through this. But thank you all.
Director Cordray, for more than a year now, a minority in the
Senate has been trying to block your nomination, trying to reopen
a debate that was resolved 3 years ago. For 3 years, they have
tried to kill that agency, and they lost that vote 3 years ago. Then
they fought to weaken the agency. They lost that fight because
they did not have the votes. And today they know they still do not
have the votes to undercut the agency, so they are determined to
hold your nomination hostage.
It seems pretty clear what is going on here. This is not about
your qualifications or your performance. Your work has been
praised by both consumer groups and by industry groups. This is
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about a minority that does not want a watchdog that will keep an
eye on big banks to make sure they do not cheat their customers.
Now, why would big banks and their friends not like the consumer agency? You know, I take a look at a few of the things you
have done in just the last couple of years. You have recovered nearly half a billion dollars for consumers who were tricked by big credit card companies. You created a complaint system that has handled 91,000 complaints last year alone. You built a tool to help students and their families compare the costs of college, what you
were just talking about, so they have better information when they
are making a big financial commitment. You have put together a
tough-as-nails office to look out for servicemembers and military
families and help protect them from financial predators, including
helping servicemembers whose homes were illegally foreclosed
upon. And you issued new mortgage rules that have been widely
praised as balanced and fair and that are clamping down on the
kinds of sleazy practices that cost millions of families their homes.
Now, that is an extraordinary set of accomplishments for an
agency that has only been around for a few years. And I think it
explains why this agency is so important. I commend you in your
work.
I think that enforcement of the law, particularly the laws to protect consumers, to make sure that big banks follow the rules, I
think that is really important. And, Director Cordray, you have already proven that the consumer agency is independent and effective, that you can be fair and be tough. But before your current position, you were the head of enforcement at the Consumer Financial Protection Bureau and before that the Attorney General for the
State of Ohio. So you know more than just about anyone else about
strong enforcement of the laws.
So in your experience as head of enforcement at CFPB and as Attorney General for Ohio, in order to enforce the law effectively, how
important is it that you have adequate resources, adequate funding, and adequate information?
Mr. CORDRAY. I would say all of those things are essential. I
think if you do not have the information, you do not know what to
do. If you have the information but you do not have the resources,
you know what to do but you cannot do it. I think you also have
to have the will to understand and be motivated by the desired result, which is people need to understand that they have to obey the
law. As I used to say when I was Attorney General of Ohioand
I feel the same way nownobody is so high and mighty that they
are above the law, and nobody is so undistinguished that the law
does not apply to them equally with everyone else. That is a bedrock of our society. It has been the strength of the American society
and American system for more than 200 years, and we have to
make sure that we maintain it. That is part of my responsibilities
at this Bureau and it is part of the Congress responsibility as well.
You pass the laws; we are supposed to enforce the laws within our
jurisdiction. I take it very seriously. To me it is a calling. I actually
worked closely with criminal law enforcement, police, sheriffs, prosecutors as Attorney General of Ohio, and it is a very important responsibility to keep faith with the American people that we not
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only have a democratic system, but we have a rule of law and it
is maintained.
Senator WARREN. Well, thank you very much, Director Cordray.
I appreciate the work that you are doing and that you are out there
to make sure that these large financial institutions do not just
treat a fine as a cost of doing business, but that they actually
change their behavior, and that consumers are entering a level
playing field and they have a real chance in these markets. I appreciate that.
Did you want to add something? We are out of time, but did you
want to make a remark?
Mr. CORDRAY. Yes, I would just say that when you are dealing
with a particular situation where there has been a violation of law,
there are sort of four pieces to it, as I see it from the standpoint
of this Bureau.
There is making sure that what is being done is not done in the
future, stopping it, whether it is injunctive relief or banning someone from the marketplace for a period of time, both of which we
have done.
It means restitution to consumers so that they are as much as
possible made whole for the harm that was done them, that should
not have occurred and only occurred because of a violation of the
law.
There are penalties that can be imposed when restitution is not
enough to sort of teach the lesson and see to it that people are deterred from doing this in the future, that they do not just feel like,
I got caught this time, but when I get away with it, that does not
cost me anything.
Finally there are cases where criminal referrals would be appropriate. We want to be very careful about that, but there are going
to be cases of that sort.
Senator WARREN. Good. Thank you very much, Director Cordray.
I am glad you are out there fighting on behalf of consumers, and
there will be those of us here who will be fighting on your behalf
and on behalf of this little agency. Thank you.
Mr. CORDRAY. I appreciate that.
Chairman JOHNSON. We will go briefly to a second round of questions.
Director Cordray, I understand that the CFPB is conducting
exams of larger institutions in coordination with other Federal or
State regulators. What steps does the CFPB take to ensure that
the exams and information requests are well coordinated with
other regulators and not duplicative?
Mr. CORDRAY. Thank you, Mr. Chairman. This is an area where
I think the Bureau has done very well, and I will just say that. I
think it is in part because, as the Bureau got underway, there was
a point made to bring some people in who came from a State government background. I myself came from a State government background, but here I am thinking not of someone like myself from an
Attorney General office, although that is important and relevant,
but people who came from a State banking background or a State
financial services background. We have had terrific relationships
with the CSBS, the Conference of State Banking Superintendents
and we have collaborated closely with them. There have been mat-
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ters where we worked directly with them and where there has been
a process of coordination and information sharing with them. At
last count, I believe we have agreements with 61 different banking
and financial service agencies in 49 States. Some States have multiple agencies. I think that that relationship is good. We lean on
them in some respects and they can now lean on us in some respects. We bring joint resources to the problems, and I have been
really pleased at their attitude toward working with us and I think
our attitude toward working with them.
Chairman JOHNSON. With regard to community banks and credit
unions that are not subject to the CFPBs examination authority,
what measures have you taken to ensure that your rules are clearly interpreted by the prudential regulators during their exams?
Does the CFPB plan to continue releasing Small Entity Compliance
Guides as has been done twice already? When might we expect to
see more Small Entity Guides on the other mortgage rules?
Mr. CORDRAY. Thank you, Mr. Chairman. I have got about three
different answers to that question. I will try to go fast.
On the Small Entity Compliance Guides, this is something we
take very seriously, and we know it is important, and we have been
told this over and over by both smaller institutions and the trade
associations that represent them, like ICBA and NAFCU and
CUNA. That means taking our rulesSenator Crapo initially mentioned 25,000 pages of rules issued in January. That is 25,000
pages of text. A lot of that is preamble. A lot of that is cost-benefit
analysis. I think when you actually translate it into the Federal
Register, it was less than 100 pages of rules, and these were seven
major mortgage rules that Congress directed us to do.
Nonetheless, I do not think people enjoy reading the Federal Register. I do not, and I am a lawyer. We have been translating those
into plain English and compliance guideswhat you need to know,
what you need to do. That is becoming a standard for us on every
rule that we publish, and we are doing Web and video things. Some
people like to get the information that way.
In terms of making sure that our regulations are administered
and examined around in the spirit in which they are intended, we
work closely through a body that I had never heard of before I
came to this Bureau called the FFIEC, the Federal Financial Institutions Examination Council. With them, we are taking the lead on
writing a first draft of what the examination work would look like
around these rules and then collaborating with the other agencies
to get that in place and to publish it so it is transparent to institutions. I think it is only fair to them, and they have a right to expect
that and demand it.
I was surprised to hear the other day we are well on track to
having the examination modules, or whatever you would call them,
ready by June of this year, even though the rules do not take effect
until next January. That is light warp speed for an interagency
group like that, and it will help us make sure that we are on the
same page. As we publish them, if institutions have reactions or
think we are not getting something quite right, they will have a
chance to kibitz in on that.
Finally, since we do not actually examine the smaller credit
unions and community banks, I made it a point to create a Com-
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munity Bank Advisory Council and a Credit Union Advisory Council so we do hear directly from them and fill in what otherwise is
a gap in not having that day-to-day direct hands-on experience
with them, and that has been very helpful to us. It has been very
insightful for our work.
Chairman JOHNSON. Senator Crapo.
Senator CRAPO. Thank you very much, Mr. Chairman.
Mr. Cordray, I want to go right back to the issues we were talking about before. I want to phrase or characterize the question I
am asking with a bit of a statement first, because I do understand
your point about needing to have data in order to make effective
cost/benefit analysis and achieve the right balance in regulation.
And I do understand that we have a dynamic developing in the
world right now with regard to what has been called big data in
terms of the phenomenal rate of collection of data about people
going on in the private sector.
Mr. CORDRAY. It appears to me, Senator, apparently it is the way
of the world.
Senator CRAPO. It is, and it is happening. That being said, I
think there still are some very serious and real questions that need
to be answered as well as perhaps dealt with in terms of the way
that the Federal Government involves itself in this entire process,
if at all. Just a couple of observations.
Nobody in the private sector has the right or the power that the
Federal Government has to force the release of information. My understanding is that you are not just purchasing the data we are
talking about from private sector collectors, but that in the examination process and in other aspects of the collection, banks and
other financial institutions are being required to provide data that
they could not be required to provide by a private sector operator.
So, in other words, the power of the Government is being put behind this data collection effort, as I understand it.
Just let me go, and, in fact, I am going to ask something at the
end here that will definitely go beyond this hearing, but hopefully
get us to a much fuller explanation of how and where we are going
here.
In another context, under Gramm-Leach-Bliley, as I mentioned,
and in many of the interactions between financial institutions and
their customers, there is an opt-out right, which does not appear
to exist in the functions that are currently being undertaken by the
CFPB. And the bottom line here, as I see it, is that although I understand the need to collect data, I am very concerned about the
heavy hand and the power of the Government being brought behind a phenomenally new, big data collection effort.
In your response to one of my first questions on this, you indicated that you were not sure whether the CFPB or some other
actor or some other contractor could go back into all of this data
and reconstruct it in a way that it was not anonymized. I actually
am very concerned about that, and now we have a Government
agency that is potentially capable, I think, of getting that kind of
information that is currently anonymized, but we just have to take
the word of the agency, like consumers today have to take the word
of private sector people that they are buying their cell phones from
or working with on the Internet or what have you, that they are
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not collecting this information in an individual-specific fashion.
And, frankly, people do not have a high level of confidence that
that is not happening. And I do not have a high level of confidence
that it is not possible for the agency to get access to this information on a specific basis.
So for all of these reasons about the data collection that is being
undertaken, I simply ask you this question and then make this
suggestion. Has the CFPB done an internal legal analysis about
this whole data collection process? And what I am getting at here
is that Dodd-Frank clearly prohibits the CFPB from collecting personally identifiable information, and if all of the pieces of information that the CFPB is collecting right now could be utilized to engage in personal identification, then perhaps that could violate the
law. But more specifically, it would be helpful to know what
stepswhat potential is there. I am actually relying right now in
this question on a Bloomberg article. That is the extent to which
I know that we know as the public about what is happening.
And so I think that it would be very helpful for us to know exactly how this data is being collected, not just who is being contracted to collect it or whether it is being collected in examination
processes, but how it is being collected and how it might be used,
and then I think the ultimate conclusion should be reached, and
that is whether its collection is in violation of the Dodd-Frank prohibition. If you would like to comment, please.
Mr. CORDRAY. I would, Senator. Thank you, Ranking Member
Crapo. A long question, and I would like to give you only a medium-long answer, but there are a number of pieces in that question.
First of all, it is not correct under the law that the Bureau cannot collect personally identifiable information. When somebody submits a consumer complaint to us, they put their name and address.
The issue under the law is that we are not supposed to disclose
personally identifiable information, and we have been very careful
not to do that and not to violate peoples privacy in that regard.
I want to go back to what you said, and I think frankly a lot of
what you just laid out is a very fair line of inquiry, and I share
your concern. If I were looking from the outside at Government, I
would share the concern as well.
First of all, in terms of forced collection of data, that is for the
most part not what the Bureau is doing. As I mentioned, the credit
card data that we are talking about we get from Argus. We buy
that. Many people buy that data from Argus and it is a very common thing. There is nothing really special about that, no new
ground that the Bureau is plowing on that.
We are buying the credit reporting data from the same source
that the Federal Reserve Bank of New York has been buying it
from for years and using to develop their reports that have been
very insightful on credit reporting and credit in the economy.
There are times where, as we examine institutions, we have to
begin by getting a baseline of data from the institution in order to
then calibrate what exactly is going on there. Are they complying
with the law? What are they doing? There clearly have been times
where we think we need a certain amount of information to do our
job, and the institution may feel like we are asking for more infor-
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mation than we need to do our job. I think those are reasonable
differences of viewpoint that have to get worked out as we work together, and I think for the most part they do.
But I would say this: I think that you have fair issues you are
raising. I would want to have the chance to have our staff get you
a very specific answer to your question about whether the
anonymized data could be somehow reverse engineered in a way
that affects somebodys individual privacy. I do think that that is
not an issue. If it were, it would have been an issue already with
other agencies gathering that same information and using it, which
they have been doing for years. It is new to the Bureau but not
new to the process.
I will have our staff spend time with your staff to dig into some
of these issues, to try to understand in more detail what some of
your concerns are. I am happy to do that with your colleagues as
well or their staffs. I want to dispel any concern on this front. I
think that what we are doing as an agency is we are trying to gather the kind of information we need to do our job the way you would
expect us to do it, to be able to do careful cost-benefit analysis,
which we cannot do without sufficient information, and to do the
kind of reports to Congress that you expect from us that will be
credible and that will give you a basis for going forward and making policy and making judgments about things like the CARD Act,
which we are going to give you a report later this year on how that
has been implemented and what some of the issues are with that,
both factual and then perhaps normative. And I know you want
that. You have required us to do that. We cannot do it without data
and information.
Again, all we are trying to do is to do our job. If there are concerns about some of the details of how that information is handled,
our Inspector General looks at these things. The GAO audits look
at our operations. You all are free to look at them. We want to be
an open book, and if there are concerns, then we want to try to address them.
Senator CRAPO. Well, thank you. My time is obviously up, and
so I cannot continue with this here. But I would like to continue
this with you, and I would like to ask you to take seriously the request that I make that there be an internal legal analysis that is
shared with us about all the details of how this project is operating
or this operation is being undertaken and how it fits with the requirements of Dodd-Frank.
Mr. CORDRAY. You tell us what you want, sir, and we will get
it to you.
Senator CRAPO. Thank you.
Chairman JOHNSON. Senator Hagan.
Senator HAGAN. Thank you, Mr. Chairman.
Director Cordray, as I said before the hearing, it is always a
pleasure to see you, and I feel like we see you quite a bit. Thank
you for the job that you are doing.
I want to associate myself with Chairman Johnsons question
about the rural definition. I have heard questions and concerns
about this definition. I was surprised to see in North Carolina several counties labeled nonrural, especially in the northeastern part
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of our State, which is quite ruralfor example, Camden County
and Currituck County. I appreciate the CFPB looking at this issue.
I want to talk to you about financial literacy. I have always been
a huge supporter of teaching financial literacy to our students in
grades 6 through 12. As we have discussed in the past, I will be
introducing legislation on this topic later this week. When I was in
the State Senate in North Carolina, we passed a mandatory requirement that schools teach financial literacy. I keep saying this
is not rocket science. We just do not teach it.
I also serve on the Health, Education, Labor, and Pensions Committee, and I chair the Subcommittee on Children and Families.
We will be having a hearing titled, The Economic Importance of
Financial Literacy Education for Students later this week.
Can you talk about what the CFPB is doing to improve financial
literacy through the Consumer Education and Engagement Division and the Office of Financial Education? What improvements do
you see taking place.
Mr. CORDRAY. Thank you for the question, Senator. This has also
been a personal passion of mine. I think it is hard to come face to
face with these issues and see how they affect individuals and
households and not be passionate about this subject.
When I was a local official in Ohio, I had to deal with folks who
were delinquent on their real estate taxes, and, you know, there is
a perception among the public that people who do not pay on time
are deadbeats, and some of them are and some of them just do not
want to take their responsibilities seriously. For the most part,
that is not the case. People are victims of either bad luck or bad
decisions or poor choices, but often just bad fortune. Every day people die in families across the United States. You always hope it is
not your family, but it is somebodys family. Or somebody gets injured where they cannot work or the marriage falls apart and there
is a divorce, and now there are two households where there used
to be one, and there may be expenses and arguing over the assets.
All these things disrupt peoples lives.
What I saw was that in all those instances issues were made
worse by the fact that people really did not understand, and they
knew they did not understand, a lot of the financial decisions they
were making, and keenly felt the self-consciousness of not knowing
what they were necessarily doing or recognizing a year later that
they made a bad choice about that mortgage or about that student
loan.
I think that one of the things that we absolutely have to do as
a Bureauit is fundamental for us, and I am going to be much
more aggressive in the coming year in using the bully pulpit and
pushing on and collaborating with officials around the countrywe
have to teach people and make available to them the tools so that
they can learn more about how to handle their personal finances.
You cannot have a free market economy, which rests on individual
decision making by millions and millions of Americans, in which
they are not capable of making sound decisions for themselves. We
do not want to have a society where people make decisions and several years later come to our Tell Your Story line, as they do every
day, and talk about how they regret the decision they made, and
if they had known the difference between a private student loan
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and a Federal loan, they would not have done what they did, but
now they are stuck with it. It is a tragedy in this country that we
would not consciously teach young people how to handle themselves when they go out in the world. They may not listen, they
may not do it, but the fact that we do not, as you say, we do not
even teach it, is just a scandal.
In Ohio, I worked for the same thing. We have now a requirement in Ohio that you have to have personal financial education
before you graduate. That was a struggle. The next struggle, of
course, is what you said. What does that actually mean and how
much is it? I was told just yesterday, when we had visitors in on
this subject, by a woman from the University of Cincinnati, that in
many districts that is going to be just a 6-week thing folded into
some other class, which is something. It is better than nothing, and
6 weeks is certainly better than zero, but we have to take this seriously. We mandate teaching of history. We mandate teaching of
Government so people can be good citizens. We also have to mandate a basic understanding of finance and a recognition that there
are going to be certain decisions you will come across in your life
that will be life-changingwhat you do about that mortgage, what
you do about trying to pay for education. Getting those right is
really not a casual matter, and it is something we plan to be a
trusted source for the resources for people to try to grapple with
those decisions, as they are doing right now with our Paying for
College module.
I am sorry. I could talk for 20 minutes about this, and would if
you did not stop me. But I think it is not a partisan issue. This
was Home Economics in the old days, and it is just basics of being
able to operate on your own. We all know, as I always like to put
it, brothers and sisters, sons and daughters, cousins, nephews, and
nieces that we know are not as well equipped as they should be
and we have a responsibility for that.
Senator HAGAN. I think you should take the bully pulpit and
really use it. I can see your passion. I have it too. I have seen so
many people that have gotten into so much trouble because they
simply were not educated. And when I say they were not educated,
they are very, very smart people, but they did not understand the
dynamics, and primarily they do not understand debt.
Mr. CORDRAY. It is complicated for people, let us face it. I used
to say when I was the State treasurer of Ohio and I was responsible for billions of dollars of public funds, and I hoped I was doing
a good job at making decisions about keeping them safe. This was
in the throes of the crisis of 200708. I would go out and talk about
this issue, and I would say, frankly, there are many things I do not
know that I wish I knew more about. Am I saving the right balance
of savings toward retirement? Do I have the right balance of insurance on my car or home or life? You know, am I getting that right?
Do we understand enough about our credit reports?
There are just a lot of things that are complicated for people, and
for us at the Bureau, it is about reducing the complexity. That is
a big part of what we are trying to do, Know Before You Owe, and
the kind of simplification and transparency of these decisions; and
then building more capability among people and giving them the
ability to have tools. Of course, people will make their own deci-
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sions for themselves. It is not going to be some nanny State deciding what you do with your mortgage, but you are the one that is
going to have to live with it.
Senator HAGAN. I believe my time is up. Thank you.
Chairman JOHNSON. Senator Moran.
Senator MORAN. Mr. Chairman, thank you very much.
Mr. Cordray, thank you for being here. About a month ago, the
CFPB released a statement stating that U.S. lenders could face litigation if they fund loans made by auto dealers that are later found
to be discriminatory. It is a huge component of our economy. I
think the number is about $90 billion. I would be interested in
knowingI do not have an opinion at this point about whether the
finding is right or not, but tell me about the analysis that was done
to arrive at that conclusion. Do you have the methodology of this
decision available? If so, what would you be able to share with that
process, either today or later with me in my office?
Mr. CORDRAY. Thank you, Senator, for the question. The issue of
indirect auto lending is one that, at this point, we addressed in a
very general way with a legal analysis that leads to a legal conclusion. It is not yet a factual conclusion about any particular instance, although there is a lot to be heard about this area as you
go around the country and listen to people, both lenders and borrowers.
The legal point we made, which I think is straightforward, is
that if you are a lender and you set up a lending program, which
involves third parties making some decisions in the program, but
it is your program and you are the one lending the money, then
you remain responsible for complying with the Federal law. It is
the same in the mortgage field. If you set up a lending program
as, say, a bank lender of mortgages and you set it up so that some
of the loans are made directly by your employees and some are
made indirectly by brokers or others, you remain responsible for
your program, and you have to comply with the law.
I think it was a fairly straightforward point, but we were hearing
from some folks who did not think that was necessarily so, that
somehow if there is a third party involved, that somehow it becomes entirely their responsibility and not the lenders responsibility. I do not think that is right. We would be happy to share the
legal analysis with your staff separately if you would like.
Senator MORAN. So at this point, it was just the legal analysis
Mr. CORDRAY. It was a bulletin that we put out, yes.
Senator MORAN. And you indicated earlier about cost/benefit
analysis, and that would come later in determining whether or not
there are enforcement actions or regulations to be written?
Mr. CORDRAY. Yes, if we were to write regulationsand that is
a possibilitythere would be cost-benefit as required by 1022 of
our statute to have to do. If we are undertaking enforcement actions, that is a different issue. It is a matter of investigating the
facts, setting them against the law, something I know you are very
familiar with.
Senator MORAN. OK. That answers my question. Thank you very
much.
Mr. CORDRAY. Thank you.
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Senator MORAN. Thank you, Mr. Chairman.
Chairman JOHNSON. Senator Warren.
Senator WARREN. Thank you, Mr. Chairman.
Director Cordray, I understand that the Consumer Financial Protection Bureau is required by Dodd-Frank to complete a study of
mandator arbitration. Is that right?
Mr. CORDRAY. It is, yes.
Senator WARREN. When do you anticipate you are going to have
that finished?
Mr. CORDRAY. I do not know that I can give you a specific date,
but it is one of the things that Congress has specifically required
of us and a task Congress had given us, so when we set our priorities, tasks Congress has given us tend to take priority over tasks
we give ourselves.
I would say we are already in process in putting together that
study. What Congress said in our statute is two things. They said
that we were to do a study of arbitration as it affects consumer financial products and services, and there are arbitration clauses, as
I know you know, in a number of different types of consumer lending contracts, and it is something that has spread in the last couple
of decades, certainly. Then if we are going to adopt policy, regulations, or some provision about what to do about arbitration clauses
of that sort affecting consumers, it should be based on the results
of our study.
You could argue this as the same kind of thing Congress says do
a cost-benefit analysis. Here they were much more specific. They
said do a full study, really look at this, really dig into it, really try
to understand how arbitration proceedings differ from court proceedings, what kind of rights they give to consumers, what kind of
rights they may take away, what kind of results are gotten there,
is that a fair system, is it reflective of the merits of the issues, or
are there systematic procedural biases that make it difficult for
consumers to get through them, who pays for the arbitration, et
cetera, and that can vary.
All of those things, study that carefully, and then do policy. They
wanted us to be very rigorous about this, and we are going to do
that.
I would estimateand I hate to estimate dates because then people hold me to it, but I feel quite surethat we are going to have
some of this analysis out publicly this year. Whether it will all be
out publicly this year, I am not sure, but we are trying to be very
careful as to what we are doing. We know that there is a lot riding
on it because then it will be consideration of policy following immediately after.
Senator WARREN. I appreciate that you take this seriously, and
I am looking forward to the study as soon as you can possibly get
it out.
I want to ask you about one other thing. I know that you have
set up a consumer complaint process and that it has some quite innovative features, and you have also made it a quite transparent
process. I wonder if you could tell us just a little bit about what
you have set up at the Consumer Bureau and what you have
found, what the response of the banks has been and how this information is being used.
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Mr. CORDRAY. I actually think we are tracking a precedent that
has existed now for about 40 years, which is the National Highway
Traffic Safety Administration. They started publishing data on
auto safety back in the early 1970s, and it was resisted strenuously
by the auto companies at the time. The sky was going to fall if people actually knew how safe or unsafe their vehicles were.
Fast forward almost 40 years later now, and that is standard. It
is accepted. It has become the basis for consumers making decisions. It has been the basis for companies thinking and looking
more carefully at their own operations and doing recalls of products
that are questioned. And it has been, I think, a success.
I have seen discussion in the last year or two, as we were focusing on our work here, that the auto companies now not only accept
it but embrace it. They think it has made their products better,
and it has minimized litigation risk for them, which is another way
it can save companies money by paying attention to how their customers are being treated. So I think it is the same thing in the financial services area.
We get complaints. We are taking them on a range of subjects
now, which is increasingmortgages, credit cards, auto loans, student loans, bank accounts, and now credit reports and remittance
transfers. We are publishing that data. We find it valuable in our
work. It is informative to us. So we think it will be informative to
companies. They can look at their competitors. Who is doing better
than I am? Who is doing worse? Why are they doing better? How
can I improve? That is the kind of competitive dynamic we want
to foster.
And, third, for consumers to be able to have this information and
look at it and potentially make decisions on it. Maybe somebody
will use that database and start rating financial products, as is
done with cars on auto safety, as I think likely will be done over
time with the Consumer Product Safety Commission as they put
out information on which toys and other household productscribs,
toasters, you name itare safe.
This is the kind of information that if I am a consumer and I am
a member of the publicand the members of the public really are
the ones who should and do run our Government, not usI would
want to have that information. I would not want my officials to
hoard it. I would want them to share it with me. I might use it,
I might not. But if I can find some benefit in it, then I would expect
them to share it with me.
Senator WARREN. And, Director Cordray, I know I am out of
time, but let me just askyou talk about the effects on the market
overall, but for individual consumers who file complaints, those
complaints are then forwarded to the financial institutions?
Mr. CORDRAY. Yes.
Senator WARREN. Have some people actually gotten money back?
Mr. CORDRAY. Many. You know, by no means all. You know, a
complaint is just that. It is a complaint. Sometimes it is valid.
Sometimes it is not. Sometimes people think it is valid, but it is
based on a misunderstanding of the facts or the law. But there
have been many situations where consumers have received relief.
Millions of dollars have been returned to consumers through our
consumer response line. And notably, and more importantthis is
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something the companies wanted us to make a change, and we did
to stress thisthey often give nonmonetary relief. You cannot put
a price tag on it, but if you get something cleared up in your credit
report where you do not have to keep calling for another 3 months
to get that thing fixed on your bank account, that is meaningful relief for people, and it is very satisfying to them.
We have had many instances of both monetary and nonmonetary
relief. We have had a lot of matters referred to us by Members of
Congress and members of this panel that we have been able to resolve, and I think it has been very satisfactory. I know there are
some that we have not been able to resolve, and I apologize for
those. But we do our best, just as I know your staffs do their best,
to help people, and that is part of what our job is.
Senator WARREN. Good. Thank you.
Chairman JOHNSON. I will turn to Senator Crapo for a brief
statement.
Senator CRAPO. Thank you, Mr. Chairman. I just wanted to follow upMr. Cordray, this is not going to be a question because we
will get together with you afterwards on the issues that we said.
Mr. CORDRAY. OK.
Senator CRAPO. First of all, we did not get into a number of the
questions that I raised in my opening statement, which we talked
about, and so I will submit those questions to you, if you would respond to them.
Mr. CORDRAY. I sure will.
Senator CRAPO. But you and I, I think we may have a disagreement or a different understanding at least as to what the DoddFrank statute requires. As I read itand I am reading the statuteit says, The Bureau may not use its authorities under this
paragraph to obtain records from covered persons and service providers participating in consumer financial services markets for purposes of gathering or analyzing the personally identifiable financial
information of consumers.
So those were the exact words of the statute. By the way, in
other parts of the statute leading up to that, it talks about voluntary information being provided by consumers, and so I again
refer to my opt-out suggestion. But I would like to get with you
and we will do thatand urge you to provide the kind of information as well as legal analysis about the departments processes here
that can help us address some of these issues.
Mr. CORDRAY. We will certainly do that. We would like to put
your mind at ease on that. I do think what you read is part of the
statute, absolutely. There are other ways in which the Bureau gets
personally identifiable information such as, for example, when people file their consumer complaints.
Senator CRAPO. But that is a voluntary action by the consumer.
Mr. CORDRAY. Yes. We are not really interested in personally
identifiable information. For us, it is just a hassle. It means we
have to make sure that it is being properly handled, that it is not
being disclosed, that we have to devote a lot of time and attention
to guarding it carefully and making sure it is handled the way
every other agency under Federal law has to handle it.
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What is insightful to us is the anonymized information that tells
us about consumer behavior, consumer harm, consumer benefit,
and that is the information we need. We do not really want to
know about you personally. We want to know about consumers in
general.
Senator CRAPO. Well, I understand that, and I trust that that is
exactly what you are all about. But I do not think just the assurance of the agency that they are not interested in it is really what
we are trying to achieve here.
Mr. CORDRAY. Understood, yes, and we will be happy to work
through that to your satisfaction.
Chairman JOHNSON. Mr. Cordray, I thank you for your testimony
today and for your leadership of this important agency.
This hearing is adjourned.
[Whereupon, at 11:42 a.m., the hearing was adjourned.]
[Prepared statements, responses to written questions, and additional material supplied for the record follow:]
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PREPARED STATEMENT OF RICHARD CORDRAY
DIRECTOR, CONSUMER FINANCIAL PROTECTION BUREAU
APRIL 23, 2013
Chairman Johnson, Ranking Member Crapo, and Members of the Committee,
thank you for inviting me to testify today about the Semi-Annual Report of the Consumer Financial Protection Bureau. My colleagues and I are always happy to testify
before the Congress, something we have done 32 times now.
Born out of the worst financial crisis since the Great Depression, the Consumer
Bureau is the Nations first Federal agency whose sole focus is protecting consumers
in the financial marketplace. We are dedicated to improving the lives of everyday
Americans and to restoring trust in consumer financial markets. The Semi-Annual
Report we are discussing today embodies our work over the last 6 months of 2012.
The report illustrates the ways we are using the tools Congress has provided us
to empower consumers and promote a fair, transparent, and competitive marketplace for consumer finance. We have taken steps to improve the workings of marketsparticularly those in which consumers cannot choose their financial service
providers.
One such market is debt collection. Concerned about systemwide problems that
pose risks to consumers, we gained authority at the beginning of the year to supervise debt collectors. The debt collectors covered by our supervisory authority account
for over 60 percent of the industrys annual receipts in that market. Bad actors in
this market are a detriment to consumers and to every debt collector that operates
lawfully.
We also expanded our supervision program to include the larger credit reporting
companies. Credit reports have a profound impact on peoples lives. Previously,
these companies were not subject to any Federal supervision, and consumers often
struggled to get errors resolved. In addition to our new supervision program, we
began handling consumer complaints about credit reporting issues, all of which will
open a clear window into the actual operations of these companies. As a result, the
Bureau can now evaluate whether Federal consumer laws are being followed
throughout the process, from credit origination through debt collection. By identifying problems and rooting them out early, we are working to minimize consumer
harm.
Our report also encompasses the Bureaus first enforcement actions, which were
against credit card companies that deceived and misled consumers. In some cases,
the companies targeted economically vulnerable consumers with low credit scores
and low credit limits. We were able to secure $425 million in relief for 6 million
consumers, and we also imposed penalties on the companies to deter such activity
in the future. These actions will serve as a warning signal for anyone who seeks
to profit by deceiving or misleading consumers.
In the second half of 2012, we also tackled issues in the market for private student loan debt, which currently totals about $150 billion. Our studies detailed the
struggles students and recent graduates are experiencing in that market. Together
with Education Secretary Arne Duncan, we made recommendations to Congress on
commonsense reforms to ensure that the risky underwriting practices of the past
are not repeated.
The work I have discussed here today is merely a snapshot of our efforts on behalf
of consumers. We also are addressing consumer complaints on a growing number
of financial products and services, totaling more than 130,000 to date. We have
adopted comprehensive new mortgage regulations banning irresponsible lending
practices that helped bring about the recent financial crisis. Our Ability-to-Repay
rule follows the simple principle that lenders should offer consumers mortgages they
can afford to pay back. We have actively conducted outreach on various issues to
older Americans, students, servicemembers, and others, and what we heard from
them has guided the direction of our work.
Each day, we take another step in pursuit of our vision to create a consumer financial marketplace where customers can see prices and risks up front and easily
make product comparisons; in which no one can build a business model around unlawful practices; and that works well for individual consumers, responsible businesses, and the economy as a whole. We will continue to persist in this work and
we appreciate your oversight. As always, I will be glad to answer your questions.
Thank you.
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RESPONSES TO WRITTEN QUESTIONS OF SENATOR CRAPO
FROM RICHARD CORDRAY
Q.1. At the hearing, you testified that the CFPB has many different mechanisms for collection of lending and credit data including: (1) purchasing data from vendors, (2) collecting data pursuant
to examination and supervisory authority, (3) collecting data from
the CFPBs National Mortgage Database, and (4) collecting data
from consumers submissions to the CFPBs Consumer Complaint
Database. Are there other ways that the CFPB collects data to
compile its Big Data?
A.1. The phrase Big Data is generally used to refer to the vast
amounts of personally identifiable information that is available
with respect to individual consumers as the result of modern technology. The Bureau is not involved in such Big Data collection.
To the contrary, except with respect to complaints (where consumers must provide their identity in order to allow the complaint
to be investigated), the Bureau generally does not obtain any personally identifiable information. Rather, we secure anonymized
data to enable us to assess compliance with Federal consumer financial laws and risks to consumers in consumer financial markets.
To date, the Bureau has received data through each of the channels you mention: purchasing data from vendors, collecting data
from supervised entities, and gathering data as part of the consumer complaint process. The Bureau also collects publicly available datasets, such as Census demographics, that are relevant to
the Bureaus work.
In some contexts, firms have voluntarily submitted data that the
Bureau requested. For example, in connection with the Private Student Loan Report required by section 1077 of the Dodd-Frank Wall
Street Reform and Consumer Financial Protection Act (Dodd-Frank
Act), the Bureau met with major participants in the private student loan industry and offered them the opportunity to provide
data on several of the 16 questions that Congress required the Bureau to answer by July 21, 2011. Nine lenders volunteered to provide their existing datasets to a single vendor that they selected.
This vendor combined those data into a single database that did
not include the identities of borrowers or lenders. This mechanism
was an efficient way for the lenders and the Bureau to develop answers to Congress questions.
Congress also authorized the Bureau, in Section 1022(c)(4) of the
Dodd-Frank Act, to collect information regarding the organization,
business conduct, markets, and activities of covered persons and
service providers. The Dodd-Frank Act authorizes the Bureau to
gather this information from a variety of sources and using various
methods including surveys. Information gathered in this way from
covered persons would be subject to the protections that the Bureau affords to confidential supervisory information.
Q.2. At the end of the hearing, you stated that you would supply
me with the legal analysis about the CPFBs process for Big Data?
Please provide any and all legal analyses undertaken by CFPB
staff and outside counsel hired by the agency regarding its Big
Data collection.
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A.2. As stated above, the Bureau is not engaged in Big Data collection. Rather, we are undertaking targeted collections of generally anonymized data to further our statutory purposes.
The Bureau has not retained outside counsel to analyze the
issues about which you inquire but, as explained below, the Bureaus staff has determined that we have the authority and indeed
the obligation to gather and utilize data in order to do the work
that Congress has directed us to perform.
With respect to the market-monitoring activities that I discussed
at the hearing, we believe that such information is essential for the
Bureau to have a deep and thorough understanding of the markets
we regulate. Congress recognized this by explicitly directing the
Bureau to monitor for risks to consumers in the offering or provision of consumer financial products or services, including developments in markets for such products or services. 12 U.S.C.
5512(c)(1). To carry out this directive, Congress authorized the Bureau to gather and compile information from a variety of sources
including, without limitation, information obtained in the course of
our supervisory work, consumer complaints, surveys of consumers
and market participants, and review of available databases. 12
U.S.C. 5512(c)(4)(B)(i). Congress also authorized the Bureau to require covered persons and service providers to provide information
necessary for the Bureau to fulfill the monitoring, assessment, and
reporting responsibilities imposed by Congress[,] subject to the
limitation that the Bureau may not use this authority for purposes
of gathering or analyzing the personally identifiable financial information of consumers. 12 U.S.C. 5512(c)(4)(B)(ii), (C).
Pursuant to 12 U.S.C. 5512(c)(6), the Bureau has published rules
regarding the confidential treatment of information it collects pursuant to its various authorities, including its market-monitoring
authorities. Under these rules, information provided to the [Bureau] by a financial institution to enable the [Bureau] to monitor
for risks to consumers in the offering or provision of consumer financial products or services is included within the definition of
confidential supervisory information. 12 CFR 1070.2(i)(1)(iv). As
with all confidential information of the Bureau, the internal dissemination of confidential supervisory information is limited to
those employees to whose duties the information is relevant, and
the external dissemination is strictly limited to certain specified instances. 12 CFR 1070.41(a). The Bureaus rules permit the disclosure of materials derived from confidential supervisory information
(e.g., reports to Congress), but only to the extent that such materials do not identify, either directly or indirectly, any particular
person to whom the confidential information pertains. 12 CFR
1070.41(c). The Bureau believes this limitation is consistent with
Congress direction to take steps to ensure that proprietary, personal, or confidential consumer information protected from disclosure by law is not made public. 12 U.S.C. 5522(c)(8).
In addition, the Bureau is subject to generally applicable laws
governing its collection, use, and dissemination of personally identifiable information, such as the Privacy Act, 5 U.S.C. 552a. Among
other things, the Privacy Act requires the Bureau to maintain in
its records only such information about an individual as is relevant
and necessary to accomplish a purpose of the agency required to be
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accomplished by statute or by executive order of the President,
and generally prohibits the maintenance of records describing how
an individual exercises his or her rights under the First Amendment to the Constitution. 5 U.S.C. 552a(e)(1), (7). Pursuant to the
Privacy Act, the Bureau has issued a System of Records Notice
(SORN) that governs its collection and treatment of records in support of its market-monitoring function. See, System of Records Notice for CFPB.022Market and Consumer Research Records, 77
Fed. Reg. 67802 (Nov. 14, 2012). In this SORN, the Bureau makes
clear that [i]n most cases, the records subject to this SORN will
not contain personal identifiers, and that research and analysis
will only be performed on de-identified data. Id.
Q.3. Does the CFPB differentiate data it obtains through its supervisory authority from data collected vis-a-vis different authority,
and if so, how? Are there internal firewalls for storing and using
consumer data CFPB collects for supervisory, enforcement, research, and regulatory purposes? Can the CFPB use the Big Data
it collects for multiple purposes?
A.3. The Dodd-Frank Act tasks the Bureau with various missions
that are distinct and yet interrelated in that information which the
Bureau generates or obtains in fulfilling one of its missions, such
as responding to consumer complaints, may be relevant to and inform the Bureaus work in fulfilling its other missions, such as supervision and law enforcement. Generally, Bureau employees may
use information that the Bureau generates or obtains to the extent
that such use is relevant to the performance of their duties. The
Bureau manages its data in accordance with the authorities under
which it is collected and in compliance with applicable law, including the Bureaus regulations on handling of confidential information, 12 CFR Part 1070.
The Bureau does distinguish between different categories of information that it may generate or obtain. The Dodd-Frank Act and
other statutes impose certain restrictions on the Bureaus use of information, and those restrictions may depend on the nature and
sources of the information. Furthermore, the Bureaus regulations,
at 12 CFR 1070.40 et seq., restrict the circumstances in which the
Bureau may disseminate internally, share with other agencies, or
disclose to the public certain categories of confidential information,
including confidential supervisory information, confidential investigatory information, and consumer complaint information. To the
extent that the Bureau obtains confidential information from other
agencies, the Bureaus agreements with such agencies may also restrict the Bureaus use of the information.
Q.4. In your testimony, you mentioned that the CFPB needed to
undertake a Big Data collection to help for economic and statistical
analyses for rulemakings. Can data collected under CFPBs supervisory authority be used for rulemaking purposes related to the
practices of the institutions being examined?
A.4. The Bureau is authorized to examine and require reports of
supervised institutions for several purposes, including assessing
risks to consumers in the consumer financial marketplace.
Accordingly, the Bureau utilizes supervisory information both to
assess compliance with Federal consumer financial law and, when
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appropriate, to assist the Bureau in research 12 U.S.C. 5514(b)(1),
5515(b)(1), 5512(c)(4)(B).
Q.5. Does the CFPB inform institutions being examined for supervisory purposes when data are collected for purposes unrelated to
the exam?
A.5. The Bureau has informed industry and the public at large that
it does have authority to use its supervisory requests to obtain information to assess compliance with consumer financial laws, about
the activities and compliance systems or procedures of supervised
entities, and detect and assess risks to consumers and markets for
consumer financial products. See, Dodd-Frank Act 1024(b)(1) and
1025(b)(1). The Bureau does not collect data that is unrelated to
these purposes.
Q.6. How does the CFPB plan to utilize the Big Data it collects in
each of the following areas: (i) research and analysis, (ii) supervision, (iii) enforcement, and (iv) regulation?
A.6. Congress has provided the Bureau with several tools for gathering information, including through examinations, civil investigative demands, publicly available sources, consumer complaints, and
through the Section 1022(c)(4) authority discussed above. Data collected using one of these tools may be relevant to both the function
for which it was collected and another related function.
For example, one of the Bureaus primary functions is to collect,
investigate, and respond to consumer complaints. Although the Bureau receives complaints in the course of performing this function,
the complaints, and the data derived from them, also support other
Bureau functions, including, for example, its consumer education
function and its supervisory and enforcement functions. Similarly,
data the Bureau gathers in examining institutions for purposes of
detecting risks to consumers and to consumer financial markets
will also often help the Bureau fulfill Congress directive that it
monitor the markets for risks to consumers.
The Bureau utilizes the data it possesses for empirical analyses
such as those included in our reports on private student loans
(which relied entirely on anonymized data provided voluntarily to
the Bureau by a number of lenders) and payday lending and deposit advance (which relied principally on data collected through
supervisory exams). These analyses may include descriptive tabulations in addition to more formal econometric modeling, which together, support the Bureaus mission to understand consumer financial markets; to monitor for risks to consumers in the offering
or provision of consumer financial products or services; and more
generally to follow developments in markets for such products or
services. These data and analyses also support policy development,
including rulemaking and any related considerations of the benefits, costs, and impact of particular rules.
The Bureau utilizes dataincluding data gathered during examinations, consumer complaints, and publicly available datato
prioritize its supervisory activities and to examine institutions
compliance with Federal consumer financial law, their compliance
programs, and the risks their activities pose to consumers. The Bureau also uses information for enforcement purposes, such as as-
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sessing possible violations, evaluating the scope of consumer harm
from such violations, and determining enforcement strategies.
Q.7. If consumer data is used in future rulemakings, will the CFPB
explain in the rule what data it used and how such Big Data improved its analysis and the rulemaking process? Will CFPB provide
sufficient information and necessary data in future rulemakings to
allow the public to reach the same conclusions as the Bureau
through independent analysis?
A.7. As an evidence-based agency, the Bureau seeks to gather data
to inform the rulemaking process. Pursuant to the Administrative
Procedure Act, the Bureau generally provides notice to the public
regarding such data when it considers using them in notice-andcomment rulemaking. In some cases, confidential data are the best
source of information on a given topic. In such cases, CFPB works
to provide as much information to the public as possible, consistent
with its obligations to maintain confidentiality.
An example of our approach is the rulemaking to implement
Dodd-Frank Act requirements concerning assessment of consumers
ability to repay mortgage loans, where the Bureau received additional loan-level data including, debt-to-income ratio information,
from the Federal Housing Finance Agency in the course of the rulemaking regarding performance of loans purchased or guaranteed
by Freddie Mac and Fannie Mae. The Bureau then reopened the
comment period to provide notice to the public of the new data, to
seek comment on its use, and to seek additional data particularly
regarding performance of loans held in portfolio. In the preamble
to the final rule, the Bureau then explained the results of the data
analysis and how it impacted the Bureaus thinking about key
issues in the rulemaking.
Q.8. Will the Bureau make its consumer Big Data collection available to researchers, consumers or others, as it has with the information in the Consumer Complaint Database? What information
regarding its Big Data, if any, will the CFPB make public, and
when?
A.8. The Dodd-Frank Act in some instances requires and in other
instances authorizes the Bureau to make information public, to report it to Congress, or to share it with other agencies. Whenever
the Bureau makes information public, reports it, or shares it with
other agencies, the Bureau takes appropriate steps, consistent with
applicable statutes, regulations, policies, and agreements, to protect any confidential information, including personally identifiable
information in those rare instances in which the Bureau collects
such information, confidential commercial information, supervisory
information, law enforcement information, or confidential information that the Bureau has obtained from other agencies.
Q.9. How many financial institutions have been asked to provide
consumer data to the CFPB, and how many of them are currently
doing so? How many customer accounts is the CFPB following on
a monthly basis with respect to Big Data it collects from data purchased from vendors, data collect from supervisory requests and examinations, from the CFPBs National Mortgage Database and
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from the data furnished by consumers to the CFPBs Consumer
Complaint Database?
A.9. Most of the data that the Bureau has gathered directly from
institutions has been as part of the supervisory process. Information about the number of institutions from which the Bureau receives data through the exercise of its supervisory authority is confidential supervisory information. Information about the number of
accounts about which the Bureau receives data through exercise of
its supervisory authority is also confidential supervisory information. For the Bureaus report on student loans, nine lenders voluntarily submitted data. The Bureau is not tracking individuals
loans.
Regarding ongoing data efforts, the National Mortgage Database
is based upon a de-identified sample of 5 percent of mortgages in
the United States. Similarly, the Bureaus purchase of de-identified
credit report data includes a sample of roughly 4 percent of consumers. These data are renewed monthly so changes in the market
can be considered for research and policymaking and each update
of the data is anonymous.
Regarding data furnished by consumers when submitting complaints to the Bureau, the Bureau received approximately 91,000
consumer complaints between January 1, 2012, and December 31,
2012. In total since beginning to accept complaints on July 21,
2011, the Bureau has received approximately 156,000 consumer
complaints. A summary of the Bureau complaint process and related data can be found in the Bureaus most recent Semi-Annual
Report
to
Congress
(available
at
http://
www.ConsumerFinance.gov/reports/semi-annual-report-2/).
Q.10. At the hearing, you mentioned that the CFPB purchases data
from Argus. Please name all of the outside, third-party vendors and
contractors and their subcontractors used for the collection of Big
Data.
A.10. The Bureau does not purchase data from Argus but rather
contracts with Argus to maintain data collected by the Bureau
through its supervisory processes.
The following other contractors (and subcontractors) are used for
the collection of data by the Bureau:
Argus Information and Advisory Services LLC (Transunion is
a subcontractor)
Blackbox Logic LLC (no subcontractors)
Clarity Services Inc. (Experian is a subcontractor)
Corelogic Information Solutions Inc. (no subcontractors)
Experian (no subcontractors)
Q.11. How many pieces of information (data points) has the CFPB
collected to date? How many pieces of information (data points) is
the CFPB collecting on a monthly basis?
A.11. The Bureau has purchased two commercially available
datasets, widely used by regulators, investors, and other private
entities, regarding mortgage loan performance. Those datasets contain fields that describe some of the basic characteristics of the
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39
loan, and on a monthly basis, the performance of the loan. These
data do not contain personally identifiable information.
As part of the National Mortgage Database and the credit record
procurement, the Bureau is obtaining all of the data elements collected by the credit bureaus with respect to the records in the
panel other than elements that reveal PII such as name or address
or social security number. Additional data elements will be appended to the NMDB from other data sources such as HMDA; the
number of such data elements is still being developed.
For the credit card database collected under our supervisory authority, we are collecting a subset of the data elements maintained
by the participating issuers. These data do not contain personally
identifiable information.
Q.12. Currently, we are aware that the CFPB is collecting data on
mortgages, home equity lines of credit, credit cards, checking accounts, overdrafts, student lending (private), student lending (Government), and deposit advances. What other areas does the CFPB
collect, or plan to collect, consumer data?
A.12. As noted, the CFPB collects data on mortgages and credit
records; we have done one-time data collection with respect to other
products (student loans, payday, and checking accounts). As part of
our ongoing supervisory work, we will, in the normal course of examinations, collect data from individual institutions in order to assess compliance with consumer financial laws, obtain information
about the activities and compliance systems or procedures, and detect and assess risks to consumers and markets for consumer financial products.
Q.13. Is the data collected in the course of CFPBs supervision duplicative or overlapping with data collected by the institutions prudential regulators.
A.13. Sections 1024 and 1025 of the Dodd-Frank Act directs the
Bureau to coordinate its supervisory activities with those conducted
by the prudential regulators and the State bank regulatory authorities in order to minimize regulatory burden. The Dodd-Frank
Act also requires the Bureau to use, to the extent possible, reports
that have been provided or required to have been provided to a
Federal or State agency and information that has been reported
publicly (see, Section 1024(b); 1025(b)).
The Bureau and the prudential regulators entered into a Memorandum of Understanding on Supervisory Coordination (MOU) on
May 16, 2012, in order to facilitate this coordination of supervisory
activities
(available
at
http://files.ConsumerFinance.gov/f/
201206lCFPBlMOUlSupervisorylCoordination.pdf).
Section
IV of the MOU commits the Bureau and the prudential regulators,
as part of the requirement that examination be conducted simultaneously; to sharing with each other any information requests sent
to covered institutions relating to covered examinations. Section V
reiterates the requirement of Section 1025 of the Dodd-Frank Act
that the Bureau will, to the fullest extent possible, use reports pertaining to a covered institution that has been provided or required
to have been provided to a Federal or State agency, and information that has been publicly reported.
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The CFPBs Supervision and Examination Manual (available at
http://files.ConsumerFinance.gov/f/201210lcfpblsupervisionand-examination-manual-v2.pdf) explains how examiners are to
scope examinations. In accordance with the requirements of the
Dodd-Frank Act, the Manual directs examiners to gather as much
information as possible from within the Bureau, other regulatory
agencies, and third-party public sources.
Q.14. Please provide copies of all contracts that the CFPB has with
outside, third-party vendors and contractors and their subcontractors engaged in or involved in any capacity with the Bureaus Big
Data collection of consumer information.
A.14. Attached are contract copies (and modifications) for the prime
contractors identified in the response to Question 10. Copies of subcontracts are not available since those agreements are between the
prime contractor and their subcontractor.
Argus Information and Advisory Services LLC (5 attachments)
Blackbox Logic LLC (7 attachments)
Clarity Services Inc. (4 attachments)
Corelogic Information Solutions Inc. (3 attachments)
Experian (4 attachments)
Please be aware that the documents provided are contractual
documents that may contain trade secrets and/or proprietary or
confidential information of private entities. The companies should
be consulted before any of this information is released publicly to
avoid possible competitive harm to these private parties.
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41
Argus Information and Advisory Services LLC
II.
AMENDMENT OF SOUClTATlONIMODIFICATION OF CONTRACT

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2. AMENDMENTh.4OO1FICATIQN NO
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CONTRACT 10 COOf
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4. REOUlSITIONIPURCHASE REO. NO
IS. PROJECT NO. (lfappic;ab/eJ
7. ADMINISTERED BY {ffotMr/han It9m 6)
COOE
See Block 16C

CODE
leFP
CONSUMER FIN PROTECTION BUREAU

OFFICE OF PROCUREMENT
1700 G STREET, NW
leFPB
WASHINGTON DC 20006- 4702
CONSUMER FINAN PROTECTION BURE.A

1700 G STREET , NW
WASHINGTON DC 20552
8. t(AME AND ADDRESS OF CONTRACTOR (No., ~. QlIIII/y, Slat. tOO ZlP Code)
(x) 9A.AMENDMENT OF SOlICITATION NO.
ARGUS INFORMATION AND ADVSY SRS LLC

50 MAIN STREET
SUITE 1175
WHITE PLAINS NY 10606- 1920
98. DATED (SEE fTEM 11)
x lOA MOO\FICATlON OFCONTRACTIOROER NO.

CFP- 12-C-0000I
_
100. DATEO (SEE fTEM 13)
COOE
I FACIUTY CooE
078531295
03/13/2012
11. TliIS ITEM ONLY APPUES TO AMENDMENTS Of SOUCITATlONS
D Theaboverurbered solicitation IS amended as set foith m Item 14. The hour arxI date spetified for receipt ofOlfers
D lSextended. D lSnDlel:lended
Offers I!VJstac:knOYlledge receipl of this amendmenl priorlo Ihe hour and date specified il the solicitation or as amended,byone ofthefolowing melhod$: (8)8ycornpleWl~
1iems8andl5,andretuming
_ _ oopiesofthellTlendment;(b)ByacknwAedgingreeeiploflhislllTleOdmenloneadlcopyoilheolfefSltirM1ed;or(t)Sy
separate letter orielellrarll \\otich indudes a reierencelo Ihe soicitaijan and amendment ollTilers. FAILURE OF YOUR ACKNO'MEDGEMENT TO BE RECEIVED AT
THE PlACE DESIGNATED FOR mE RECEIPT OF OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESUlT IN REJECTION OF YOUR OFFER. Ifby
lIi!\leofthls~youdesire\o ch!J1ge~cffetaireadysubmitted ,such changemay bemadebylelegramorletter,JTO-Medeadltdegtllmorlet1ermakes
refereoce 10 the scicitation and this ameodment. 8nd is received pria !othe opening h<:u and date speci!ied
12. ACCOUNTING ANO APPROPRIATION DATA I" r8Q1Jired)
See Schedule
13. THIS ITEMONLY APPUES TO MOOIFICATION OF CONTRACTSIOROERS. IT MODIfIES mE CONTRACTIORDER NO. AS DESCRIBED IN ITEM 14.
~ A. ~8~~1~ ?::~: ISSUED PURSUANT TO: (SpocifyalllllorityJ THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT
8. THE ABO\IE NUMBERED CONTRACT/OROER IS ~OOIFIED TO REFLECT THE ADMINISTRATIVE CHANGES(SiJdr as cliangesin payingoll'ice,
ilpproptialKmdale, etc.) SET FORTH IN ITEM 14,PURSUANTTOTHEAUTHQRl TYOFFAR 43.103(b).
C. THIS SUPPl.E~ENTAI. AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY Of
D. OmER (Spedfytypeofmodificationandaulhority)
i!lisnoL
O IS~d!o$lgnthisdoc:umeota~dretum
cop!es!othelSSUnlJ ofIice
I . DESCRIPTION OF AMENOMENTIMOOIRCATlQN (Orr}aniZfld by UCF secIion fINdings, ioclvding soIidtationlr:ontract subject malterwfttlll! feasible.)
RMR Collection and Analysis of Credit Card Data

1.
The purpose of this modification is to change the COR identified within paragraph 7 , 1
of this contract .
Mr . O'Mealia is replacing Ms , Xiaoling Ang (who replaced Mark Egerman) .
Attachment 1 to this modification provides a replacement page for page 19 of the contract ,
2 , Note : Modification 0002 exercised CLINs 1001 through 1010 , funded by line 0002 under
Block 19 of the award SFl449.
3.
No other term or condition is changed.
Continued .
158. CONTRACTORfQFFEROR
16C.OATE SIGNEO
03/20/2013
NSN7540-01-1 52-8070
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Previouselitionln.lsable
42
,l<;E
REFERENCE NO OF OOCUlolEHI 8ErIG COIfIWEO
OF
CONTINUATION SHEET C~P- 12 -C- 00001/0003

Of OffEROR 0/1 CONlR...cWR
IN~ORMl\TION
lIND MNSY SRS LLC
ITOMNO
SI.FI'lIESIS6II'I:;ES
'"
lSI
OO~~
ICI
11:00 Jun 14, 2013
UNITPRU
~oo.
IFI
lEI
Credit Card Vendor : NO

Period of Perfomance : 03/15/2012 to 03/14/2017
~~."J.II)IIl
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""01
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~E
'>'RGUS
43
CFr]U4>JI] . ....~OOI]l .... ~"'..J~s...-w;)

~ 7'_'_ A~"""'~"'",,*"'(CN./OCi_
!iI!_.A-.lO'-"";eow. .. ,.,...
1,0
CONTRACTING OH ICH'S
npR~S~NTATlV~
(COR)
Ll~SI GNATIO N
AN D
AUTH ORITY
7.1
The ConirnclinS Officer'l Rcpru.rnl;l!i,e for Ibi! COOlracl is Mr. Scan O'Mca!ia, and
em be reached ;l! 201435.7118. ~I !_ Xiading Ang i! the ACOR, and can be TtOCM 81
202,435.7686.
7,2
PerlOnr.ancc of",,,,llr.I>01 be , u*ClIo lhc ""hnica l dircrlioo of!be (O R idcnl ifled.

or '''f'<I'<cnlali,t dq;ignalcd m",riling. The lerm "1Ccllnical di rrcli(:ll~ i!\Clod""
v.ithoull~il;l!ion. diroclion 10 tile Contrxlor lh;l! dirccl> or m.tircc1; Ibe 1300. eITort.
>hills Ibe worl. bct",ccn v."<lrl. area! or Iocalion!, filk in delaik, and'or ()(/le .... is/: !CT>c.;
10 m.ure Ihal ta;l.; ootlincd in lhe eon\f3C( an: accomp(i;1icd ;ali;faclOrily
7.3
To: hnical dircclion IT...'I be
~'i lbin
the ~ Of lhc oonlllloCl. Technical dircclionlT.ay
be 01111 01 in writing, The COR -<Mil oonfirm 0l1Il direclion in ..Tiling wilhin fi'e
v.oo.dllyS, The COR docs IIOl M\C 8ulborily lO i!.sue technical dirccliOll Iba!:
Cmolilulc.; I ellange
or
a<.~rnl
01 addilional "orl ool!idc lhe
~ u"C!I""n'-';
(on.lilulc.; a change a, defi ..,d in the d.I>Oe enlidcd "'Chang""";

C3U.\C.\ 3 c~se in tile Cootrxl price 0I1he lilT.c required forpcrlOnr.allCC:
ChanS"" .ny of It.: lrnr.>, cMd ilioll';. or req";mr.rnll of lhe conlracl:
(nlcrfcro; wilh It.: COOtrac\Ol'. riglt 10 pcrfonn undcr tile lenT., and cMdilion!
of the c01llracl; OI
Direct..., !'4"'"i!<'S, 01 OIhcrwi", oontrol. lhc ocliml
or
the Contrxlor'>
crr.pIoyoo..
1.4
Th~
COIIII\leII)! >IIaI1 pro.'I'l'd ~plly ~'ith p!'I"f(ll1l'.lIIICe H'l'IJ lling &om lhe I"dmi[!(ll
dilCo:lion i~wed by iIle COR. If. in the opiniOll or ille Cootractor. ally diroclion Oflbc
COR. 01 designee, fa lls ",iill in tile lill'.ilalioo, in rmsrap/11.3 herein. It.: COOIraciOJ
!IIaII immediately Jdify lbc OO!1 lll1oCling o/T,cer 1](} lale. iIlan II>:: bcgiroing of lhc nnl
Go,c-mtr.cn l ,"-oil day
7,5
h il"", M lhc CootrackM' and lhe conlracling om"", lo .gn:e lhal k'dlnic.1 dircc1ion i.
within !be
or lhe conlraet .hall be '"~Co:I
lO
lhe
1(Tll'~
of the cia""" enlidcd
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"/Ji'put",."
44
II.
AMENDMENT OF SOLICITATlONIMODlFICATION OF CONTRACT
I~' EFFECTIVE DATE

See Block 16C
CODE Icrp
2. AMEtDMENTlMOOlFICATlON NO.
0004
6. ISSUED BY
IP~E
CONTRACT 10 CODE
PAGES
4. REQU1SITIONIPURCHASE REO. NO
15. PROJECT NO. (Wapplicable)
7. ADMINISTERED BY (ffotherlhafillem 6)
CODE IcrPB
CONSUMER FIN PRO'l'ECTION BUREAU

OFF'rCE OF PROCURF..MENT
1700 G STREET, NW
WASHINGTON DC 20006-4702
CONSUMER FINAN PROTECTION BUREA

1700 G STREET , NW
WASHINGTON DC 20552
8. ~E AND AOORESS OF CONTRACTOR (No.,.stm/, ooullfy, 51l1taand ZJPOJd!)
(x) 9A. AMENDMENT OF SOUCITAllON NO.
ARGUS INFORMATION AND ADVSY SRS LLC

50 MAIN STREET
SUITE 1175
WHITE PLAINS NY 10606-1920
H)A MODIFICATION OF CONTRACTiORDER NO.
CFP-12-C-0000I
COOE
IF
ACIUTY CODE
078531295
11. TH
03/1312012
ITE
.Ie:; Tu AMENDMtI'I...:! ~':It ::KJLK;1 , ... " u N::;
D The above nulTbered soIici1aoon IS amended as set forth 1Il1iem 14. lhehoura!lddatespedfiedforrec:e.ploiOlfers
D lSextenoe.:t D isnatexlended.
OfferslTlJslackrowledQereceiptoithisamer'l:htlef1lpr'atothehou"a!ld4a1espedfiedin Itoesolidlation or as amended,by one of the following methods: (a)Byco~1"9
Items 8 and 15, and relt,rning
_ _ _ copies of1he amendment (b) By aclmoY.1edging receipt rJlhis amendmenl on each COW of the otfer smmilted: or (e) By
separate letter or lelegram v.tlid'I hdudes a re!erence to the solicitation alld amendment numbers. FAILURE Of YOUR ACKNQv.tEDGEMENT TO BE RECEMD AT
THE PlACE DESIGNATED FOR THE RECEIPT OF OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION OF YOUR OFFER Ifby
IIlrtue rllhis amendmen1l'Ou desire 10 chllf'lll!! an Offet already subrritted. $IJch charge may be made by1elegram orlet\ef, pro'<'ide<! each telegram Of IetIer makes reference
to the solicitatiOn a"'Id this amendment. and is received prior 10 1he opening tlour and dale spedfied.
12. ACCOUNTING AND APPROPRIATION DATA(lfrtquiffld)
See Schedule
13. THIS ITEM ONLY APPUES TO MODIFICAT1ON OF CONTRACTS/OfiDERS, IT MODiAES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITM 14.
~ A ~g~~~ ~~E~~ ISSUED PURSUNfTTQ: (SpecifyaulhorilyJ THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT
B. THE ASOVE NUMBERED CONTRACTK>RDER IS MODIFIEO TO REFLECT THE ADMINISTRATIVE CIWffiES(svch as c:JJangesin paying offlce,
approprialion date, f!~} SET FORTH IN ITEM 14, PURSUANT TO THE A\JTHORiTY OF FAR 43.103(b).
C. THIS SUPPlEMENTAl AGREEMENT IS ENTERED INTO URSUANT TO AUTHORI YOF:
E. IMPORTANT:
I! hsroi.
Conlrador
O lSreqWredtoSlgflthlSdlXumenta"'ldretum
oop!eStolhelSSUlr.golb.
14. DESCRIPTION OF AA4ENDMENTIMQD1FICAT!0N (Organized by UCF section heacPngs, indu~ng so/ialalioM:onlfactsubjectmatter..mere feasble.)
R."l.R Collection and Analysis of Credit Card Data
1.
The purpose of this modification is to change the COR identified within paragraph 7.1
of this contract.
Ms. Kirsten Ling is replacing Mr . 0' Mealia,
Attactunent 1 to this
modification provides a replacement page for page 19 of the contract.

2.
No other tern or candi bon is changed.
Credit Card Vendor: NO

Period of Performance: 03/15/2 012 to 03/14/2017
Exrept as pro.;ded herein, all lem1sa"'ld conditions ofthedoaJmerrt referenced in Ilem9AorlOA,asheretolorecltanged,remainsurx:halgeda"'ldinMlforc:eandelled.

15A NAME AND TITLE OF SIGNER (Type or pfiflQ
TinE OF CO
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158_ CONTRACTORIOFFEROR
45
CFr'U4>JI' . ....~""'( .... ~"'..J~s...-w;)

~ 7'_'_ A ~"""'~"'",,*"'(CN./OCi_
!iI!_.A-.lO'-"";eow. .. ,.,...
1,0
CONTRACTING OH ICH'S
npR~S~NTATlV~
(COR)
I)~SI GNATION
AND
AUTHORITY
7.1
The Coolracting OlflCCT'! Rcprc!Cnlali,'e f'" Ih~ COO lracl is Mi. KiTSlcn Ling, and CM
be ",ached 81 202.43'.7201
~K
Xiaoiing (Ling ling) Ang
Ihe ACOR, and can be
readied 31201.435.1686.
7,2
Pcrm03n<:C of,..",llr.I>01 be .\ubjcclro Ihc Ihnica l direrl"'" of l(w, (OR idcnl if,ed.
'" rcprc<eruali,t dq;ignalcd
m,..riling. The lerm "1Ccllnical
din:clioo~
inclod""
diroclion 10 !be Contrxl'" lhal. direcl> <lr m.iirtt1! Ihe 1300. eITort.
>hills Ihe worl. bct",<Cn ","<lrl. area! or location!, filk in delaik, and'or OOlerwisc !m':';
",ithoull~ilation.
10 mourl' Ihal ta;l.; oollincd in Ihe eonlf3Cl an: occOll".pli;hc<J ;ali,faclOrily

7.3
To:hnical direclion IT...'I be ""ilhin the ~ oflhe oonllllCl., Technical direction Ir.ay
be oral 01 in ",Til,ng, The COR -<Mil oonfirm 0l1Il din:clion in ..Tiling within fi'e
",oo.dllyS, The COR Qoo. not M,e 8ulborily 10 i!.iue lechnical din:clionlhat
Cmoliwl':';
change or
a<.~rnl <lr
addilional ""'. ool!idc 11K:
~ u"crr.cn'-';
(on,liwl.:.; a change", defi..,d in lhe oI...,e enlilled "Chang"'";

Cau.\C.\ 3 chMge in !be Coolf3Cl price '" lhe lilJ".c ~"ircd f",JlCTIOnr.allCC:
Changes .ny oflhe lrnr.s. cMd itioll';. or n:qu imr.rnll oflhe Contracl:
Inlerfero; ",ilh III: COOtradOl'. riglt 10 perform undcr !be lenT., and eMdilion;
oflhecOIIlrac~ OI
Din:ct.\
!up""i~
01 or!J;:n.i", control' !he aclioo.l or lhe Con!nIClor\
crr.pioyoo..
1.4
Th~
COIlIr\lelI)! >I!aI1 pro.'I'l'd
~plly
""ilh p!'I"f(ll1l'.lIIICC H'l'IJ ltirog &om Ihc k'chni[!(ll
direclion i~wed by the COR. If. in lhe opinion of the C001racl0f. ally diroclion Oflhc
COR. '" designee, fall! ..-ithin!be lill'.ilalioo, in rmsrapil1J herein. III: COOIraclOl
!hall immediately Jdify tbc con lracting off,cer JI(} lalcr Ihan II>:: beginning of the nnl
Go,crnll'.cnl ,"'oil day
7.5
hi l"", M!he ContrackY and l(w, controcting om"", 10 agn:c lhal k'dlnical din:clion i,
willl,n 11K:
>C~
of lhe eonlraet .hall be
'u~cel 10
I(w,
1(Tll'~
of the cia""" entided
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iIr ~ <::l!dit ani 0IjIL!IInI. '!be <teM ani ... '"" .,11 c:oqlI:-s1I!ady ~
_ _ ameIIy c:oIlcaed by llIir6-pIIrIy ogrq;m for Iloo DIpnoaI 01 "'" T.'-i'
'*" ......u..
Of!ico oflloo ComprroIIef III W CImrq (Ot'q. Tho ooc --.dy

mdiI CII'd _from ... (9)01Il00 bqaI cndiI Old ..., 0IIl000I bd:IlIuccI .. a.ImI
diu. tad dof.mti<n ... 1DOaIhly ItW. Tho a..w IboI provide IIw CFPB willi mdilconi taLa
~ diffmnl fro:n Ihc bulb IhII comnlly pWVirlt aLa II> IIw occ. ThoI<rVic.;nckde, \I0Il
"" ILQIlimitet 10:
~
oIirecI ___ 10 lilt Ba!b 10 moi'oe daa ...,. _
ud ....
.....-.vAo..... 10 Lt.e0'l'll for frio< ~ dua opliIy:

~ . . lObt-.l .. Cf1'II"""'""'IIIId.~II>I!Ic~
ol"f'Ol"lOD:lwlr.i<al~
u..u:.g tilt IedmiclI ~liIy b
Ibe <bca ooIltcteJ from Ibe Sanb II> o.lbI.."td
wi'" tho oa:.llId b lIitU'1inJ bD: daq Ihat ill p!OI'idId by Ibe OCC I""""'"
\I) ""
OX"""' M~ of ~ (MOO) btl ..... ilIo OCC ad
0",
~..,..a.iII
pII>Oidiq __
.. IIFoaIDd . . . . . . 1M
...w...o ,mol _
IIfIQ _ _ _
IpIq' ..,.
"'I'
ad_ ...... eo! rltliac ......

LknrttINd. daq _
. . . . prt'iousIy u...iIwd dal. . _mi!:lJle~,.,
It.. ~-.b--bued JIIW!Il win b< xtUSo:d by ~ JltI:l'Y LI!C1 \I) "...dlx:I
JlI'II'f*
.x!iMI
~ <:lOCIIO
oogcing ~ ODd risk baMd wl,U
VerDate Nov 24 2008
11:00 Jun 14, 2013
Jkt 048080
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,.1-'..-_ ......
70
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r _ f_ _
-'-_ ~ "' _ .Cnitc.o "",,
II
Tb< eo._1bI!! ~ .. eIocIr<:ocio; i:lll!faoo ret fiJi .. <11 r,o!oooi<l of porioI.i;:

rqlOIt. Itt credi! cord data. Tho ""IiI)' ond ",:iabilit1 of the duo l1l&I1 bo dIotUd ..
pol! " ~ CoaInoIor'. aadtbe Olll'"
)J
data vaIidatioo px:cIMI.
lk eoa...... ...,. bo ~ by" Cl?B ...... cftdiI cord c!a coIlockd
1diiIiomI......- co:a.. diR<Iod
r-
by !lie ~ Oll"lm',
R"I'f<I"'IMi~ (COlI} No otlMr ptnIIQtaI."trues wi Ul'llhe 'uIl:oriIy 10 rtqII'II
...,.;c.., Of deli ....... :rndcr the_II> bo ......'1Icd.
lho 80nb wido
).4
........
crPB',
~ (lOt Of . . .
01 lito
....me. Uc ........ Brio, ..
a.rmal mM. 1lIIY bo rtpbtod by ..:<be< bank. I. ado

coJ~ionl
QSo$, ~
""I' be ~ for lOJIOIIiq ~ods arlitt oJo/.., the _
dora
,ward dolo
I"rotn Ihar. boob.

)j
....w
AD efta Ce.racI" ..n ~ IdlleclIO ebo _

Iri! \IdoIc .....
CffR All _~ nit, 0IId ..n paformod lor. _ O'PII .iD ......
coolidttlliol ...II "' ooIy be dit:1oIod .iIh pri(M" wriuor: pamUsicn from the CfPB.
Th< ec.- will pafi;n.olJ wort .. ill OQ f&ciOtios.
4.1
Tho edi, CIfd duo elt:r.em ddh,,~ons .... ~"btd ill ~ 4. A W

dkIiooury~ tbedala I)'pn <l1be ,~, II .......:11 ~ if..-.ilJble it
Al!Io:/II:ItS S. ~1tvoI.a-ia will K atbMtd III dIo CFi'B by ... apbIcoI
r..x. i!to "'"""" ....6 CId (Ibt

a.ms 1to.. .",.;J !he bill <II)' of ....
~ .,.. .. IIICII:3Iy ..........

"AI <I 0...'"), 0. OIOd!".Iy tow. lhertl,"',1lto
om IOOllI!t a!Ier Iho I""YiwlIlIOIlIlt" md III submit the <lilli- a. "Repatiq OMI."
The BIIlb 011)" ~Ie Ihe diu r.. lito pmiouo t:lilIlIIt .., Iiat dmio& lito ~
..... AI Dl<ded.1hr s.b.,.,. ___ . . filios, ~ oflhcit _...,.;rd Of
.... ~oflheO'PB.
42
The fM!rXIDIlhllliUbmi! p<l!folio-lcwI doI.I to !he CfP8 q\W!crty by tho montb
..u... foIlo-aittt! tk c..c of 1M p.:hIit ttl.... ri dto 1I#.b' ~erly eartIlI:JI

. - 1M <Id":IiIioM .-I _
of ~ IIdricI .. <b:ribtd in
Alrldt:tJmIs 4 !lid '" lk Catnaor .till dtIri, ,.mas. doll _
.. 01 ....
cod forQ;!! IIXIIIIIt il lit qIII<I.
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'WOP!<, ,.aIidate, 1tM, ,dn.\,UIlc! "'pori (10 dora ..1in cIio:ussed ,....iIl, Tho
I).... .a:J ... II'Iilal>k at rady .. ooIIoa, ~ nlido:o, .:m. mn... mil '<pOll
eM <Old ..... ~ widoll:r ~ hcRm. ....
...,.~.,.
lfIa _
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.wU The COIItrIOtOt ..\OG Icr tIId
..,
~ ~
IDd
~.
IIO:f data ........, idattifiod ..
1Io1m IIpIII<piaIo. &lid "'D lhe
c.n.::.:. IIIOJ" derM cnio iIcmI ;. .... 10 ....an _
,no.
app<I'a1 of !be COR. lilt

0di0iIi0u lad ....:-y
..,:11.
OCIllA !be IWQ (e.I- ...... daily bolJoco, Tho: map;rin:a cJ m.i1 _ " 10 I """"
doEoilicc). AU _
~ ":.11 k rtpOII<d by IboIIIIIIb -= wtiJ III aD
COIIInOa
"""-~'O'\Itioi!le~"'"""...""
... dtIoud, Jddili<:nal
....
~.........,~
au ........,. Of j>CtIfoIio IypCI . .y be oddeoil<l "" xopc: oi dIIIo
<XII.Icniao III!! ,..t0ltti0n. A"'f Iddilioaal data ei_1Dd porJo:io !)'pel adGtd 10 IlK obtJ
coIIenio:Jootd~.,.Ibo~oiIbtOOR.
"'l~ &lid i"dtdo.:! iQ ~ ~ fiud
..lI ... ~"_I!ot...,.oi
..
.m jfices. III ft< "'"'" ..OUt dofG_
IIItd '" be cUnt<d Of doll ,m-. need 10 be oddt<I, Ill< CFPB !III)' a>nsUlt with tbt
CaIncIor, Ira fin&I oIctioio.. tie IIlf d<f.:iIa ~ .... ..u Il1o tll'B. As JIll' oiIM
~ ~ !be Cr.tIInaoIIhatl (iIO'ido Tho: ~1l1llu i~ tho ,~
ICW.tIt ~ prO>'idtd (A1IXIIao:nI 6~ The em_ IiWl f(lliow lilt """"'11
dQcriIIed II !M dolo dtfiIiIicaI and ""~. Tho COOL...... *all pwvido or pcrfcnI
-*>ollbr tI!b li!:cd below.
HI
()l
I OIClIIhIy It,,,io. cal ltrt Ioon-IfflI ODd portfolio m<lit CIId
..ma..cdoa. MIbo a..u """" .. .,;rior ..........

md r.acI)o to rmiw cilia ..",;n, 110 lat<I' iIwl <hilly
iIfIa' _
..... Tho C -'. 1)0l<OI mo.lI!
oeppIO ....... wifI die ..._ ... ;nMkd 10 . . oa: by ....
5.1.2 Be
I"';Wl~
~ ~
boW. 'n.. do'. - Ihouk! be
,bI. to ....r;repttd u.d _I '"
. . . . t.a. noedod.
HJ
Rooeiw lIIODlhly ~h"" from 1hI: Borb !qin.mc Ihr firll" t\'<l)'
Ib< pmiou!-'>", d.:a.
-u h
j.
t..
DrI~k,:> cd U#)nblc tho IAA<:!W'td fOOl'l1I1 (q. rltlitnlltd 1<>1 ro"-l

NrMllbelllililfdh ... ~_~m..m.1lIIIb
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"'Ien..------
72
_ _ _ _ ............. _ _ "o..t;"Ir.,
(:fP ~~_0011""-t_UCl
~
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H1 IlmIvo Illy 'oW ~ iIDeI of d=Ia haM ... fur.NI,

MUmR. ~1DII qua/ityof.. dIIa rn.!he a..bbosod ..
Iho 0l'B ~ III!! dIa 6dioiIioDI.
5.1.1 Work ...illo dx IIriIlD adlieve data ..bmiaiuo~;" bolt<! ..

..,. odCi!i<u, ~otaiow, lid dIrifJ;aioos to 1bc ..............
~Of~"""'r"""""'hoylhoa..
n9 Wan: ,.;(, lht 11mb 10 f."i\J1It dill
ruppq II1nIfOfr:ll;Iion of
t~!_liftc\t~"~to~oriir""
c-.-', daIa o;oDectioo . . . . . ad,...,......
5.J.!0 CoIkcI Cftdi om! dill !Mrn .... lIIII:or dispante iDforlJlllion
oymr. bDr.! (00 Ib: Boob' iofc,r=-io:r J)'>ftIl
lJ,llotuioOOR'f'IIIO"l! I(I,,,.rtIII\r:oissionof duahoy' zj,m

bti, ad ~ dxlp;l!Ol'rir.e ""P~ ~ 1(1 ~fy
Ill<
f:r lit rm:brroiAiolL
nil AuisI ~ Brit wrdr d:e ~ .,.t

iII!mo.btely ""'" _
..."ITd.
.-moo
fi""
nil wort ...... Barrb 10 oIoodop -1nte!I' 1Id]llla rL I<Iioo if

ooIl~ nq'Jlled daIa ,Icr.<ra tb ... ,."........,. milIhIo b
...
8m'
ThtCoou&Cll:t wiIJ Q(lt \It r""",,~d drul"""",
IIlOdifJ'iol
>IlY do~ nola! ia tho BW:s' I)'JICIIIl.
1Iown.... Iho C - - l1:li JID6!y _ Cf1'9 rL A:Io f:.tiocI
<)"I'''',
rw.c
lhrw;l- rr,xwu oiaMS<d ia Sio:a ~.9.4.
VerDate Nov 24 2008
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5.1.14 Coli! lid Io\-..qt ....,....10\'\1 cro:!il ""'"'" IIl:'itIWs b

u)IAW d4lI....t,W ~ nt c.o.-n:w IIooI! bt """"""...
73
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..........
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fa"~" ~ ~orlCOlll:ll Womauoa 10 . . . . ~ ...

"",ill ,..,.-'1), mrnbers, I\.lI:'IU, ~ baol _ 1 rMl:bcn
",u be ~ UIIdof 1M
Coan1ct. (Gioa: !he ~,~ __ 0( dIU -""";""_-kwI
0llIu ~ idomifi ..... ~
m.liI Io:rou
proMo:!
1It1l""'" 10 be co/IO<'Itd b\' 1ht C<n:ram WI be
ti JO'_~f","ishe<!
;"fCflNtioo
5.2.1 TIlt eo-- 1lioii c...toa. ~ wri5aIioa
of {OIIt".o<I
.II .,....
pm:<U..,......:I_
be"'" 1Obnini....... 10 tIot (''fPB. Tho: c..r_ ... aohcI tOo

_ YalidaIiM promo r.ilhin ~ bo$,- OIY' 0( Iho reputjnl dMe. Tho
eo-- .dull nIidIIo !It ...
froaIlhe 80nb io _
01 da:a
.Iommi ~ ......... It!ti 01 ... ..... mol drfinil.- io

AnathrnmlS 4 IrId ! mol ~ fodd ~ r.:I cmsninll. The
C",*_ !NIl !ill III ... ~ """ dof.ni!ioDJ (~ 4 oad 5~
~
fidII,.;r- mol _ _ &d..,my,..;.. ___
\lldlll"" toIbwi",g;"r.. b"1ho
l<1>li_ 0I1ile VIli<brioo
.... _
FoUI.fI*ik .... ~""*
Ad
Iq'OI1I:
o(. . .;a nIid du;
Idcruir.<I\ign of dlta!hac iI..,. rnilabJe f ~g ~ <3=.

"' OI!I ........... ooIltewd;
Edit doodr I<fIII'II 0I00ri1'yiq '" bHI"d ad porIfoIio ... tboI

if """"pi 1M' foiled;
DIll !raid '"?'fIS 10. iftro>- ia.u.:. _In:i<<rI; ad

DoIa~ity~IOfIYb - s.l:~
5.2.2 The
CoolS~
WI pWI'ido 1ht edil ad <lata
twiY ftpMIlO tbo CFPB
....... "'*- tIy$ oM .. rqronir:&"" n...a.., ;npas IIpCIIU

r<mediaioo " odI mol dill. qQ/ity ..... NIl be . . ._ ....tIr.
\Ibm no r,~ 1>1.. bco:a ..\Imi.~, the rtp<III slWl .. nect !!Iii foe:!. The
<II . .
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~1ha!I;
74
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_ _ r_ _ _
~"_<lt;uIt(Jol"""
bc:x2.P ..o!yIiI-.ic$.
1.~ til
illirialill of edilW Uta
eo.-',
q~lil)'
rule! butd .. 1M
or.:! ~ rho ..... 1il>!1 bo
ioWopc:Iblo ";111 pRICCiiICS amIII!y in
II<
wid: aioIiac CJedit <:n
o!.utolk<:rial ~
Mike r~.. III rho CFPB for !bt ~ or
~ c-..d odiC or.l
<!ala qouJiIy l1li<$ booocI "" 1M
C:--',UfICI1iIt MiI"'-1ocDod &- . . . . die s.b.

Sr:pp:rr It. .!diiim of ... -.r.td o6t II:d .... qua!iy NIls ..
.. til .. 1M modifoioo. 0< ddttiQn of nUti.'Ig Nic:o.
~ Illy -.lditicNI <dO: .-I 4u qmIi!y naIe$ )'II'(/"idcd by dIo
CfJ1I "" ....... - . AllIWilo:mI raIa oItaI1 bo ~
ixo rho CaIncw', .,.- ..;m. ........." aflwlllo mp:Il
~OIIIII:eCfPB .
'*'
......... Ul'J aiIIiq <diI rod

q'.oaIity me r- kilt ~',
IJ'1IaII wiI:'>ioo .. u.... Nys.~.
b:wrm'll
froG !be m'I:\.
'"""*
I'rovidt quarterly rqI(tIli$tin, 011 edillild data q~ilY IlIk$, ~Uido

loa", bee; ~ dr...t (If ~ rror.w Qoah:Ior'.
1IV111 .. wdI .. rho dao III kr iat;lk ........ .,.&5cMioo
""""
U) Tho Coon:IcI: au ",baIil:M lira ".wrIy rq:a1 of aU odi nI dill quIIily
rdu 00'" rba Dry

~Iy
~.,.....,..
rq:a1 sI'..aII be ... 01 II:c
bo~ 0(
Jtrri
~,!!Io
tult ~ qIIWI'.
n.
Co:mcttr shall oti~", uy lft.... isUns boa ..... reillimstlipi ~'illo rho &lib
.. ordor 10 fxili:::IIt <!ala
~~.
Tk
Ibal be
....... fi:r ~ w COR <III)' oocaary .-diIIIoa <I r.iW

~ dill qa:ity rv!a.
S.2.4 Tho Cormcttt .... 0 ""lII: "';:10 W. O'PB 10 01<1* !he dlII roIloctioro ..t
*'II)u:aI doIU f ..... oM ~ Itt aediI en -a baod ..

dIo .f..ro. ,.....;.IaI by rho CFPB. no. Coan<:w .rba.'I ...... ..,.:n,.
l-.nflCIIlioa IOId ...m ...-idI .. y I<qUI:ed ,...b:ni1liMo ill OIlIer 10 .... rho data
,...ry f Ibc g..-.eraPoo of ooaIyI1<II fq)(IfII or .w _
...;n,in ~
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"""-' .,.. Utc:c II< . . . dole. t10r Ccu:X\OI" !WI . . .
75
t]'t.<K_IOI.o_IOII-, _LlQ
_ - . _ - - . ......... _ .........
S..O...\._~_
~0.10""'''''''
~ ltaiwd .. ~ a. ,. drfad IIy Do.iIlra 4IDikd .....)

-..i!hio fuW' I:uIi!icsI days if rer..bmi.ions om.. ,ftcr me inm.l leD ;...;....
....
ns
Tho
WJI proviok. Da:l Qu.lity M~ P!Jn...tOm-..in

1he """","",!If Mich
fer Ilw. V~ al<I
lh<...--
VaiIico!ioe ..... -'- o..rit tho -*'IoIocr fcr ......... qoMry

...,.;~~ pro<m. Tho Dab QuaIii)' M~ I'll!! WlI dNcribt tilt
iqI!cmm:,;jop InII ...u.:..-:. of IWIaIa:td vtIidoIiGn 0( the: AiL Tho
c_.n dIo~"'''-bJ'..wcIo .. ~ .. o...

VtIlduion !Cd Vtrlf"*",,,.on be mol iMo~,. Dab Qgt!"..,. M..........
PIa. T100 Ilw. ()IWiIy M..,....,t shill tho i"dlldc !be ~ nidi
.;a ... a'MdIO@lo~data......,..1Od IO_~

quality dInIIOI In'fII fer ,Jl *:i~ ~ ....... 10 tIC Dab
q...Wy ~ PIao IhtIIIIc ",bmltliCllO tho OOR fer ~ JRr 10
................
l.l.! Tho COllft:lcr Iho!! """"" tnd rnairto:. tile ~....w 10 """"""'"
t!oo !lib sa fIInh by .... I'trfomuate Wid Stacmall (PWS~ whirlI ~
COlfJIIioeolit doiI So:Iioo It.. , . C_1t.IIl tdd bI:Q Ibo ~ CftOfl
card <Ia!:a ... !lot bi!rJ::,rkai <tedit bI:ro.rJ 1t:'11ue! 10 Ibt OPB's J)1t0fll
r<pOIitory "" !II<r thm tlUrty QIendor dlyI tfttr _
.ward. This
pro;o.Iy aIIloctaI .. .."..pIN ok& (iIiIIooiaI atdiI CWII . . IIi\I cndit

..... aIlMIa).,l be Jlftl"idal1O tU Coaru<tt!lf till COR...;u l1li
QIm;!jr~)'I of (W'.tJCI lwald . Oov.nut:m:fW'ltiJ/le(l tar""", ..... Tho
eor.tr.:u IiIIII iI<:uporw . , _ _ tIIii hisIcrieoI
<d dati _
~
t!oo 0"PIr. oywa:J ~. Tht IIi!t<ri<II \!.Ill ir"IIh1m dtocdoed ..

!be mil, liM of <lola dtmw, (... At!aobrnw. 4 IIId '1 dmoS (rem I
ItpIWIiq paiod ti Io&ry 2(I(l8 10 !ho ~ Tho ~ oediIl7.naol
q frnco lilt m. ~ of ZG09 10 j:ftOOd -..ill be

pn!'1ded .. 00vcm!r,ml.!'wnW>ed 1Lf<n:OOon. The ..... hio:orical dolo 10
~ by'" 8&bfer _-kod -.I ~-.J dol:! ~
. . IIIriIcIa
~1_of~J11~of~~1pIICt
Histori~
VerDate Nov 24 2008
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rnuilrnittod &II. reqllll<l an
~1011l! ~ ~
of
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76
-. -.-
.............."r..o.o"""
CfP.'l<"_"""'_"'~_u.q
~r_,-..-,."..,....,.....
IIIIwrioed 10)' lie 8anb
.eor.Ii:a ... SOl Wl>l.... cr! ~ ...
II*" 1lQl1iO ThoI)"lkIllIin:I,ooatJ:y dewLbld by all "'i'.."f ~ ill

obu. .. IIia<ricaI cndiI
I!Ir 1'\\'5 . . 'Ril' 10 1M -...nc..l o;ndiI
r
b.>r=1IC~itwt "' Wl."'Y"""" weo&.""ttd iI!bofut_ TbCcrm:to
IIl>II ..uia Ll "'.......,.. ao.d taII~ of tb< IJ.W;, f td"t.'mOt
an
.-
SJJ AI "-Ind IIIIiI ~-.J Ua lid 10 all au ~

(;';h:sive of hillOrit&l d.~ dWt \.t 10 J...ary 2OCJ6, !I#'mt:Ul d&ta
po"O'I"idod by "" CFf'B, !lid data pr<n"i6od by die BI:Us) . - :cIIMI "'"
the CcoIn<:Ior t!l:o lif. oft!:e O(IOU3\I, All ",",,IMI rod ;lOI1folio-itl-.1 daIa
IDd.III doll ~ st.d IIoIniIIIIIt I"c:rlbo fit of"" - .... "' . . io
r'fIO"S, lid It QIII!fioI ~ nlnctl _n"be.! ~ IlIc I'WS. r....Ic>d ..... IIIIl biIIorio:aI brHoYd 11m from IpUiflC ItplIIilf ;oaiodI
- . . . . " ....
(tuhmisDocM ~ .......... ) cdlened..x. !be _
quc:ies 0IId Wl"0CIl, 10 desI:ribtd lhrwPo-.II "" pws, lilly 110 arclIival, .."
WlI..c 110 ~ . . . prior ""1M 1RfOI"I_1bc COL
i l l Tk c-..... ... ,..,.-idt ltJc ens nil. MIChel ofIII oIoIa(loc-leool
IUbmissioao aad mubmis>iIQ, portfof.... lowI, 0:>;1 JQ.-qMns~ m~ of
IIisI<ri:II daodWt; \.tloJa. y m,~"'""",~1I)'1Ioc
am, IItId daIa r-illcd II)' Iht 8anb 01 "" md 01 !be ~ pcrlomua
pcnod. no 01lO' poiDII of
_(l\Ib ...... IDf,...ao."II('j...n-.~f~.--.
DI trUSllliu<ao.
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TI.SK) ~ ~. The Contractor """ FfOvide a 6of...moo <If I ,",-Ie!tpXI

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he: ~ "*'r 10 ...... lUll rhirfy <IIcaIa:.",vi!.
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type,
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ATTACHWENrl
DATA MANAGEMENT PLAN
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127
(]'!'.I
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111IS PAGEll\'TENTIONAU YLEFT BIMoX
128
CO~FIDEHTIill
C'
ARGUS
K- Data Management Plan

CO llectiM, Tril nSlTlission, Validation, Aggl'gatiM, Reporting, Slora,;e aooAna!ysis
of Credit Ca rd Oatil
Off""" . . gIlS lr1:OrlNl~OI1 &j\Jj'I,iSOl'\'~!
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SoIknltiQn HFP-t2-R-<tOOOl
129
CONFlOEHTW
~afldTlldrrNrk
~ 0 lOUNf./Jr~tioo1~Ad'riooryServices,
lie. H<l Pi" ~tMdocummt
nt,
be ~prod\l~. storf<j ." I [etoM IYI'emor tr.rmitt.~." ''''lie"" 01 b'/11\f mum.

e'fttrlWlk, medl;iniul.. p/IOtOCOll'l1".. ~ [e(or$1t or otht<wiSt wIt!owt otrItten
p"million from AlI\II.
....-
uc.
.... "1 ~ I ~ trICI!ma't 01 ......... tdorrrMlanand NMoorySeMtti,

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ArfIJl tnlarmadon & kM\orySeMtti, UC

SO Mlin Slree\
So"Re 1175
Whitt' PlIoIm, 1fI10606
(914))0'/-1100
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(II/mot: "'1<11 WlY.lNtion & Advisory Smko.

SokbtiorrICfP-I2-MXml
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130
TASL OFCONTENTS
' ill! 2g/ 29

l. DfU ~_ i'M
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OlftlOf:,I,/Jvs lrf_.ilion " A6'1i1OtY SerYicti

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131
COhl lpENTW
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S/lroclttloo _CfP-1H.cron
(. Om MWlerr.trll Plan
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OIf~ ,vtLll W(II''''''lion & IuMl4lry Sertite'l
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137
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CONFIOINTW.
138
COlfR""tmA L
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1Iot._f(~""_~"""",
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ctr.. e<: ""'" Wormllion & AIMsory Strtict>

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()I!eror ""'" ~,
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DATA QUAIJJY MANAGEMENT PLA.'l
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CQNFIQ(JITIll
r';1
WARGUS
L- Data Quality Management Plan

Collection, Transmission, Validation, Aggregation, Reporting,
Storage and Analysis of Credit Card Data
ou ...or. A'IVIIf\f(M'rM(;on & AdvilOt'yStMm

Solki'.niorl, CI~l1-R.(((IOt
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ORGANllATIONALCONFUcr 01' INTEREST DlSCl.OSIJREI

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CONFIPP'lTl4l
H- Organizational Conflicts of Interest

Disclosure
Collecticn, Tran~ml!.sloo, Validation, Aureptkm, ReportinC. 5torige and ArIllysi~
of Credit Qrd Om
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F- Key Personnel
CoIection, Tl'lInsminion, 'hlldr.ion. Agregation, Re;lOltirc. StoraBe and.wtym
01 CtI!dit C41rd oau
ctt.or: ........ 1:'IfurNI1ooo "oIoIMsory SeMte!.

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Blackbox Logic LLC
I t CONTRACT 10 CODE
I PAGE OF PAGES
4. REQUISITIONIPURCKASE REO. NO
I I
I
15. PROJECT NO. (If appbbM)
1. AOMIN1STEREDBY(.Ither/tlanI/em6)
coo, iSPD
AMENDMENT OF SDLlCITAnONIMODIFICAnON OF CONTRACT

1~ EFFECTlVEOATE
2.AMENDMENTIMODIFICAnQN NO
0001
10/05/2011
COOE LSPD- AZOLLER
6 ISSUED BY
Bureau of the Public Debt

Division of Procurement
Administration Branch

Division of Procureme nt
Avery SF
200 Third Street
Attn : A. Zoller
Avery SF
200 Third Street
Parkersburg WV 26101
8. NAME AND ADDRESS OF CONTRACTOR /No.. SheI, CO\IlI)". Slll,utld l1P CldI)
(xl
SA. AMENDMENT OF SOLICITATION NO
SLACKSOX LOGIC LLC

1200 11TH STREET SUITE 880
DENVER CO 80202-58 26
!lB. DATED (SEEfTEM tl)
IDA. MODIFICATION OF COHTRACTIORDER NO.
TPD- CFP- 11 - C-0012

lOB. OATEO (SEE ITEItf f3)
CODE
jFACIllTVCOOE
004938321
09130/2011
O TheaboYel'l.ll'flt:ler8sok:ita1ionlli~a5setIorthI'lItem14. Thehourandda(eIpldfieclb"IDpta/OOers
D tSextena~.
D llnoIlxlended
O!Ier$mU$l~dgereceiploflhi.amenctneotj:QJr\o"'l'IolI'anddlte~edin .... 5OIk:tta!ionorlltlllll8l1deG,byonea/lh8fo1ow!ngmelhods: ('IBycompietiog

copie$o/thermendn\e(\t(b)ey~glngreceiptolttj.amendmen1011eactlOlpyctltlBoIIer&l.tmlted:or(c)8y
l\em.e.,dlS,andrelooWlg
separate letter ortelegwn which incIucIesa reference!01he lIOIicitalionand amendment mtnbel'l. FAILURE OF YOUR ACKNOWlEDGEMENT TO BERECEIVED AT
THE PLACE DESIGNATED FOR THE RECEIPT OF OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN RE.ECTION OF YOUR OFFER. Wby
Yirtueollhisa'Tl8l"lClnentyoude"lod\angeanctlef~IUMlitled.sud"ldlangellllYbemadeb'flelegramorlell .., prOYIdecIe8Chle~orletl"lTIIkesrr.erenc:e
!O""so5dtItionandlhi$~andilreceivedprior!olhtopenilghcManddaiespedfied.
12. ACCOUNTING ANO APPROPRIATION OATA (/I reqWed)
See Schedule
13. TKS ITEM ONLY APPUES TO MODIFICATION OF CO NTRACTS'ORDERS. IT MODIFIES THE COHTRACT/ClIUlER NO. AS DESCRIBED IN ITEM 14.
~ A. THIS CHAHGE OROER IS ISSUED PURSUANT TO: (SpedfyIHlltMyJ THE CHANGES SET FORTH IN ITEM l~ ARE MADE IN THE CONTRACT
-_._.
ORDER NO. IN ITEM lOA.
B. THE ABOVE NVMBERED CONTRACT.()RDER IS MQOFIEOTO REFlECT THE ADMINISTRATIVE OiAttGES(such as cnanges in paying alb.
appropriation date, IIIC.) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.1ro(b).
C. THIS SUPPlMENTAl AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF
14. DESCRIPTION OF AMENDMENTIMODlFICATION (Orga~led by UCf secIion headings, incl!lCing SQfcilatioob:lrltract subject ma/lef whefe feasible.)
The purpose of this modification is to change the Contracting Officers ' s Technical
Representative (COTR) from Rich Horn to Xiaoling Ang. Xiaoling can be reached at
202-435 - 7686 or vi a email at Xiaoling.Ang@cfpb.gov,
Period of Performance : 09130/2011 to 09/29/2016
15.\ NAME AND TtnE OF SIGNER (Type orpridJ
1SA. NAME ANDTTTlE OF CONTRACTING OFFICER (TypeorptiriJ
158. CONTRACTOR/OFFEROR
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283
11.
AMENDMENT OF SOUCITATIONIMODIFICATION OF CONTRACT
i;'
2. AMENDMENTIMODIFICATION NO.
EFFECTIVE DATE
0003
6. ISSUED BY
CODE
4. REQUISrnONIPURCHASE REQ. NO
04/18/2013
IBPD-RDILLON
7. ADMINISTERED BY (lfolherlhan Item 6)
IPAGE OF PAGES
PROJECT NO. (If applicabfe)
IBPD
CODE

Di vision of Procurement
Avery 5F
200 Third Street

Divison of Procurement
Avery 5F
200 Third Street
Attn: R. Dillon
8. NAME AND ADDRESS OF CONTRACTOR (No. "'"'- """"Y. StaIoItId ZIP Codo)
(x) 9A AMENDMENT OF SOLICITATION NO
BLACKBOX LOGIC LLC

1200 17TH STREET SUITE BBO
DENVER CO 80202-5B26
9B. DATED (SEE ITEM 11)
CODE
CONTRACT 10 CODE
lOB. DATED (SEE ITEM f3)
FACILITY CODE
00493B327
lOA. MODIFICATION OF CONTRACTfORDER NO
TPD-CFP-11-C-0012
09/30/2011
11. THI ITEM oNLYAPPUESTO AM ENDMENTSOF soUCITATlONS

OThe-'numberodsolici1ationisamendedasseiforthinttamI4. The hoJ,and dale spec;roed fa receipI of Off...
O~ex1ended. Oisnotex1ended
Offers musl ed<rWIedge receipl rllh~ amendmenl prior 10 Ihe hoJ, and date specifoed in Ihe soIK:ita!ion a as arnandod. by one of Ihe following melhods: la) By """plating
Items 8andl5.andrelllning
_ _ copiesoflheamen<fmenl;(b)Byad<nowledgingreceiplof~amendmenioneachcopyoflheollerS<lbm~ed; a(c)By
sep<nI.~tteratelegram wtlicI1 includes a reference to Ihe solicitation ancI amendmenl numbers. FAILURE OF YOUR ACKNOVvl.EDGEMENT TO BE RECEIVED AT
THE PLACE DESIGNATED FOR THE RECEIPT OF OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION OF YOUR OFFER. by
virtue of Ihis emendmenl you d.... to c:Ilange en oller already S<lbm~od, SlJCh change may be mode by telegram a lette" provided eech telegram Of letter makes reference
to Ihe SOlicitation and Ihis amendment. and ~ receivod prior to Ihe opening hoJr and date spec;roed.
12. ACCOUNTING AND APPROPRIATION DATA(" required)
See Schedule
13. THIS ITEM ONLY APPUES TO MODIFICATION OF CONTRACTSIORDERS. IT MODIFIES THE CONTRACTIORDER NO. AS DESCRIBED IN ITEM 14.
~ A lm8E~':~~ ~~~Ef~ ISSUED PURSUANTTO (Spedfy authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT
B. THE ABOVE NUMBERED CONTRACTIORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as cl!anges in paying o/fial.
approplilllion dafe, e/c.) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b)
C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF
D. OTHER (~fy fypaof moc1i6callOn and autholify)
E.IMPDRTANT:
Contractor
!!lis no!.
copiestotheissuingoffa
Ois'BGU"edtosignlhisdoannentendretum
14. DESCRIPTION OF AMENDMENTIMODIFICATION (Orpanized by UCF section headings. incfucfing soiicitallOn.tonfract wbjed ma/le( wile.. feasibfe.)
The purposes of t his modification are to:

1. Appoint Jessica Russell as the Contracting Office r's Representative (COR).
be reached at 202-435-7771 or via email at Jessica. Russell@cfpb.gov.
2. Appoint Xiaoling Ang as the Al ternate COR.
via email at xiaoling. ang@cfpb . gov.
Jessica may
Xiaoling may be reached at 202-435-76B6 or
Period of Performance: 09/30/2011 t o 09/29/2016
Except as provicfedhenln, aUterm. and conditions of the docunenl referenced in Item 9AOf tOA. as heretofore changed, ramains II1Chenged and infuillorce and effect.
1SA NAME AND TITLE OF SIGNER (Typeorplint)
tSA. NAME AND TITLE OF CONTRACTING OFFICER (Type orplint)
JACOB C. OBERLIN
158. CONTRACTORfOFFEROR
15C. DATE StGNED
16B. UNITED STATES OF AMERICA
t6C. DATE SIGNED
?~
4.18.2013
~01~~
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STANDARD FORM 30 (REV. 11).83)

P,esaibedbyGSA
FAR I4BCFR) 53.243
NSN7~1.t52-l70
284
r'
I;'
EFFECTIVE DATE
0001
PAGE OF PAGES
CONTRACT 10 CODE
AMENDMENT OF SOUCITAnONIMODIFICAnON OF CONTRACT

2. AMENOMENTIMODIFICATION NO.
4. REQUISmONIPURCHASE REQ. NO.
X'
PROJECT NO. ("applicable)
04/18/2013
COD~ IBPD-RDILLON
6. ISSUED BY

Di vison of Procurement
Avery 5F
200 Third Street
Attn: R. Dillon
7. ADMINISTEREP BY (" oilier //Ian Item 6)
IBPD
CODE

Division of Procurement
Avery 5F
200 Third Street
8. NAME AND ADDRESS OF CONTRACTOR lNo. """ """'Yo _ItIdZIPCorJe/ .
BLACKBOX LOG I C LLC

1200 17TH STREET SUITE 880
DENVER CO 80202-5826
9A. AMENDMENT OF SOLICITATION NO
98. DATED (SEE ITEM 11)
lOA. MODIFICATION OF CONTRACTIORDER NO
TPD-CFP-11-C-0012
120002
lOB. DATED (SEE ITEM (3)

CODE
IFACILITY CODE
004938327
09/13/2012
11. THIS ITEM ONLY APPUES TO AMENOMENTS OF SOLICITATIONS

OTheabOve"'mberedsoiicilBllOl1umended ....lloI1hn Ilem 14. The hour end dal. specifl8d far recetpt of 011....
O'S.xlerded. O~nolexlended
OIlers mus1 acI<nowfedg. receipl of !hi, emendmeni prior 10 !he hoor and daI. specifl8Cl in !he soiicilation or .. amended. by one of !he loIlowing melMds: (a) By completing
11ems8andlS.endrollming
_ _ copiesoflh.amendmenl; (b) Byad<nowleclgingrec:oiploflhisamendmenioneachcopy of!heoffOfsubmillad;ar(c) By
separat.Ie1IOf or lelag.... whidl include. a reference 10 !he soiicitalion and amendmenl numbers. FAILURE OF YOUR ACKNOVltEDGEMENT TO BE RECEIVED AT
THE PLACE DESIGNATED FOR THE RECEIPT OF OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION OF YOUR OFFER. If by
virtue of Ihis amendmenl you desir.1O change an offar 'Iready ,"bm~ed, such change may be mad. by lelagram or ~H"', provided ..eIllalagram or ledar m,kes refer""""
10 !he solidlelion and Ihis amendment end is received prior 10 Ihe opening hour and dala specified
12. ACCOUNTING AND APPROPRIATION DATA (If tequired)
See Schedule
13, THIS ITEM ONLY APPLIES TO MODIRCATION OF CONTRACTSIORDERS, IT MODIRES THE CONTRACTIORDER NO. AS DESCRIBED IN ITEM 1"
~ A THIS CHANGE ORDER IS ISSUED PURSUANT TO: (Spacily aulhotity) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT
ORDER NO. IN ITEM lOA.
.
B. THE ABOVE NUMBERED CONTRACTIORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes in paying oIfice,
apptOpIialion dale, aft.) SETFORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b)
D.OTHER(SpaciIy/ypeof_lionandaullloti/y)
E.IMPORTANT:
ConIradot
l!I~not
copieslolheisS<Jingoff....
Oisr8CJl"edlosignlhisdocumeniendrelum
14, DESCRIPTION OF AMENDMENTIMODIFICATION (Of9aniled by UCF section heedings, inducting sclicilaIion.tontraClsubjact mailer wIIeIe Ioasible.)
The purposes of this modification are to:

1. Appoint Jessica Russell as the Contracting Officer's Representative (COR).
be reached at 202-435-7771 or via email at Jessica .Russell@cfpb.gov.
2. Appoint Xiaoling Ang as the Alternate COR.
Jessica may
Xiaoling may be reached at 202-435-7686 or
via email at xiaoling. ang@cfpb.gov.

Period of Performance: 09/30/2012 to 09/29/2013
ExcepI .. providedhllfein, aalllfm.endCOt'dilionsoflhedoc:umenirefarendedinttem9AorlOA.ashereio/,,",cI1anged,remains~andinfulifarceandeffect.

lSA NAME AND TITlE OF SIGNER (Type or plinf)
16A NAME AND TITlE OF CONTRACTING OFFICER (Type Of plinf)
JACOB C. OBERLIN
158. CONTRACTORIOFFEROR
1SC. DATE SIGNED
____
1SC. DATE SIGNED
r~____
4.18.2013
l_oICotIIrdIgOb:!
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STANDARD FORM 30 (REV. 10.83)

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FAR (48 CFR) 53.243
NSN750Cl152ol1070
Premus ediIion unusable
285
DEPARTMENT OF THE TREASURY

BUREAU OF THE PUBLIC DEBT
PARKERSBURG, WV 26106-5312
September 30, 2011
BlackBox Logic LLC
ATTN: David Feiner
Subject: Award of Fixed Pnce Contract
Contract #: TPD-CFP-11-C-0012-loan Level Mortgage Text File Data
Dear Mr. Feiner.
Congratulations! BlackBox Logic LLC has been selected to fulfill the requirement for Loan Level
Mortgage Text File Data sets for the U.S. Department ofTreasury on behaff of the Consumer Finandal
Protection Bureau (CFPB). We are enclosing a copy of the award document.
Please review the enclosed Contract and ff in agreemen\ please complete blocks 30a, 30b and 30e on
Page 1 of the.Standard Form 1449. By signing the SF1449, you acknowledge and accept the terms and
conditions of this Contract. After signing the document, please retum a copy of the signed form back to
me either electronically at psb3@bpd.treas.govATTN: Angie Zoller or via fax to (304) 48()'7204.
The designated Contracting Officers Technical Representative (COTR) will be Rich Horn. Rich may be
contacted at
Consumer Financial Protection Bureau
ATTN: Rich Horn
Fifth Floor
1801 L Sl NW
Washington, DC 20036
PH: 202-435-7406
Email: Rich.Horn@treas.gov
A copy of the deSignation letter that details the COTR responsibilnies and the scope of their authonty are
enclosed for your records.
Mr. Alan Dotson will be the Governments Administrative Contracting Officer (ACO). He may be reached
at (304) 48()'7206. Ms. Bemadette Kem Will be the aHemate ACO and she can be reached at (304) 48()'
7003. All administrative staff can be emailed at contractadministration@bpd.treas.gov, referencing
Contract# TPD-CFP-11-C-0012 and the correct contact name in the subject line. The fax number for all
contacts is (304) 48()'7204.
If you have any questions conceming this award, please contact Ms. Angala Zoller at (304) 480-8954 or
psb3@bpd.treas.gov, referencing Contract # TPD-CFP-11-C-0012 AZ in the subject line.
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Enclosures
286
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287
2 of
21.
22.
QUANTTTYUIIT
21
utlTPRICE
This IDIQ contract is awarded for a bq.se year of

12 mont;hs and four option
ye~r
periods .
Funds will be obligated when a task order is

issued.
Task order.s may be issued for any items/services
listed on Attachment A - Master Service
Agreement.
Contracting Officer Technical Represesntati ve
(COTR) is Rich Horn
202-435-7406
Rich .Horn@cfpb.qov
Technical POC:
Ron Borzekowski
Phone : 202-435-7381
Email : Ron.Borzekowski@cfpb,.gov
Invoicing will be in advance at the 'beginning of
the each month for all re'quirements except
Professional Services.
Professional services
will be Net 30 in arrears .

Supplemental Clauses, PWS, and Master Service
Agreement are attached hereto and incorpQrated.
Continued ...
32aQUANTITY INCOLUMN21HASSEEN
DRECEIVEO
D'NSPECTEO
ACCEPTED,AND CONFORMS TO THE CONTRACT, EXCEPT AS

DNOTEO
32b.SIGNAT\JREOFAIJlliORIZEDGOVERNMENTREPRESENTATlVE
32c. DATE
32G, MAllINGAODRESSOF AIJlliORIZEIlGOVERNMENTREPRESENTATlVE
32~.
PR NTED NAME ANDTlTlE OF AIJlliORIZEIl GOVERNMENT REPRESENTATIVE
321. TElEPHONE NUMBER OF AIJlliORIZED GOVERNMENT REPRESENTATIVE
32g.E.J.IAll.OFAlITHORIZEDGQ\o'ERNMENTREPRESENTATIVE
33. SHIP NU~IElER
~. VOUCHER NUMBER
l5,AMQlJNTVERIFIED
CORRECT FOR
o COMPLETE
DPARTIAl
DPARTlAl
DFINAL
38.SlRACCOUNTNUMBER
39. 5IR VOUCHER NUMBER
I37.
I
CHECK NUM8ER
40. PAD BY
41a I CERTIFY THISACCOlMr IS CORRECT AND PROPER FOR PAYMENT

41b, SIGNAT\JREAMlTlTLEOFCERTlFYINGOFFICER
DFINAL
42.1. RECElVED ElY'(Prim)

41c.DATE
42b.RECEIVEDAT{l..tlCatiMJ
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f42c. DATE REC"O (yyM!MlOJ
288
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10. )1 ..,,..0 .....
291
52.212-4
CONTRACT TERMS AND CONDITIONS -- COMMERCIAL ITEMS (JUNE.2010)
(a) Inspection/Acceptance. The Conlractor shaH only tender for acceptance those items thai conform to Ihe
requirements of this contract The Government reserves the right to inspect or test any supplies or services
that have been tendered for acceptance. The Govemment may require repair or replacement of
nonconforming supplies or reperformance of nonconforming services at no increase in contract price. If
repairlreplacement or reperformance will not correct the defects or is not possible, the Government may
seek a"nequitable price r~duction or adequate consideration for acceptance of nonconforming supplies or
services. The Government must exercise its post-acceptance rights(1) Within a reasonable time after the defect was discovered or should have been discovered; and
(2) Before any substantial change occurS in the condition of the item, unless the change is due to the
defect in the ilem.
(b) Assignm~nt. The Contractor or its assignee may assign its rights to receive payment due as a result of
performance of this contract toa bank, trust company, or other financing instiMion, including any Federal lending
agency in accordance with the Assignmenl of Claims Act (31 U.S.C. 3727). However, when a third party makes
paymenl (e.g., use of the Govemmentwide commeTtial purchase card), the Contractor may not assign ns Mghts to
receive payment under this contract.
(c) Changes. Changes in the term_
s and conditions of this contract may be made only by written agreement of
the parties.
(d) Disputes. This contracl is subject to the Conlract Disputes Act of 1978, as amended (41 U.S.C. 601-613).
Failure of the parti,es to this contract to reach agreement on any request for equitable adjustment, claim, appeal or
action arising under or relating to this contract shall be a dispute to be resqlved in atcordance with the clause at FAR
52.233-1 , Disputes, which is incorporated herein by reference. The Conlractor shall proceed diligently with
performance of this conlract, pending final resolution of any dispute aMsing under theconiracl.
(e) Oefinftions. The clause at FAR 52.202-1 , DefinItions, is incorporated herein by reference.
(Q Excusable delays. The Contractor shall be liable for default unless nonperformance is caused by an
occurrence beyond the reasonable control of the Contractor and without ns fault or negligence such as, acts of God or
the public enemy, acts of the Government in either its sovereign or contractual capacity, fires, floods, epidemics,
quarantine restrictions, strikes, unusually severe weather, and delays of common carriers. The Contractor shall notify
the Contracting Officer in writing as soon as ~ is reasonably possible after the commencement of any excusable
delay, setting forth the full particulars in connection"therewith, shall remedy such occurrence with all reasonable
dispatch, and shall promptly give written nolice to the Contracting Officer of the cessalion of such occurrence.
(g) Invoice. The Contra'ctbr shall submit an original invoice a'nd three copies (or electronic invoice, if authorized,)
to the address designated in the contract to receive invoices. An invoice must indude0) Name and address of the Conlractor;
Oil Invoice date and numbe"
Oii) Contract number, conlract line item number and, ~ applica~e, the order numbe"
(iv) DescMplion, quantity, unn of measure, unit pMce and extended pMce of the items delivered;
(v) Shipping number and date of shipment, including the bill of lading number and weight of shipment if shipped
on Govemment bill of lading;
(vi) Terms of any discount for prompt payment offered;
(vii) Name and address of official to whom payment is to be sen~
(viiQ Name, tffie, and phone number of person to be notified in event of defective invoice; and
(ix) Taxpayer Identification Number (TIN). The Comractor shall include its TIN only ~ required elsewhere in this
contract.
(x) Electronic funds transfer (EFT) banking information.
(A) The Contractor shall include EFT ban.ng information only ~ required elsewhere in this conlracl.
(8) If EFT banking information is not required to be on the invoice, in order for the invoice to be a proper
invoice, the Contr!3ctor shall have submitted correct EFT banking infomiation in accordance with the applicable
solicitation provision, comract clause (e.g., 52.232-33, Payment by Electronic Funds Transfer-Central' Contractor
Registration, or 52.232-34, Payment by Electronic Funds Transfer-Other than Central Contractor Registration), or
applicable agency procedures .
. (C) EFT banking information is not required ~ the Govemment waived the requirement to pay by EFT.
(2) Invoices will be handled in accordance with the Prompt Payment Act (31 U.S.C. 3903) and Office of
Management and Budget (OMB) prompt payment regulations at 5 CFR 1315.
(h) Patenf indemnity. The Contractor shall indemnify the Govemment and its officers, employees and agents
against liabilily, including costs, for actual or alleged direct or conbibutory infMngement of, or inducement to infringe,
any United States or foreign patem, lrademarl< or copyrighL aMsing out of the performance of this contract, provided
the Contractor is reasonably notified of such claims and proceedings.
(i) Payment. (1) Items accepted. Payment shall be made fot items accepted by the Govemment that have been
delivered to the delivery destinations set forth in this contri3ct.
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(2) Prompt payment. The Government will make payment in accordance with the Prompt Payment Act (31
U.S.C. 3903) and Office of Management and Budget (OMB) prompt pay regutations at 5 CFR 1315.
(3) Electronic Funds Transfer(EFT). If the Govemment makes payment by EFT, see 52.212-5(b) for the
appropnate EFT clause.
(4) Discount. In connectiorlwith any discount offered for early payment, time shall be computed from the date. of
the invoice. For the purpose of computing the discount eamed, payment shall be considered to have been made on
the date which appearS on the payment check or the spe~fied paymnt date if an electronic funds transfer payment is
made.
(5) Overpayments. If the Contractor becomes aware of a duplicate contract financlng or invoice payment or
that the Govemment has otherwise overpaid on a contract financing or invoice payment, the Contractor shall(i) Remn the overpayment amount to the payment office cned in the contract along with a descnption of the
overpayment including the(A) Circumstances of the overpayment (e.g. , duplicate payment, erroneous payment, liquidation errors,
daters) of overpayment);
(B) Affected contract number and delivery order number, if applicable;
(Cl Affected contract line nem or subline nem, if applicable; and
(D) Contractor point of contact.
(il) Provide a copy of the remittance and supporting dO(:Umentation to the Contracting Officer.
(6) In/erost.
(i) All amounts that beoome payable by the Contractor to the Go.vernment under this contract shall bear
simple Interest from the date due until paid unless paid within 30 days of becoming due. The interest rate shall be the
interest rate established by th.e Secretary of the Treasury as provided in Section 611 of the Contract Disputes Act of
1978 (Public Law 95-563), which is applicable to the penod in which the amount beoomes due, as pro~ded in (i)(6)(v)
of this dause, and then at the rate applicable for each six-month penod as fixed by the Secretary until the amount is
paid.
Oil The Government may issue a demand for payment to the Contractor upon findinga debt is due under the
contract.
(iii) Final decisions. The Contracting Officer will issue a final decision as required by 33.211 if(A) The Coniracting Officer and the Contractor are unable to reach agreement on the existence or amount
of a debt within 30 days;
(B) The Contractor fails to liquidate a debt previously demanded by the Contracting Officer within the
timeline specified in the demand for payment unless the amounts were not repajd because the Contractor has
reqt,Jested an installment payment agreement or
(C) The Contractor requests a deferment of collection ona debt pre~ously demanded by the Contracting
Officer (see 32.607-2).
(iv) If a demand for payment was previously issued for the debt, the de'mand for payment included in the final
decision shall Identify the same due date as the original demand for payment.
(v) Amounts shall be due at the earliest of the follOwing dates:
(A) The date fixed under this contract.
(B) The date of the first written demand for payment, including any demand for payment resulting froma
default termination.
(vi) The interest charge shall be computed for the actual number of calendar days involved beginning on the
due date and ending on(A) The date on which the designated office receives payment from the Contractor,
(8) The date of issuance of a Govemment check to the Contractor from which an amount otherwise
payable has been withheld as a credit against the contract debt; or
(C) The date on which an amount withheld and applied to the contract debt would otherwise have beoome
payable to the Contractor.
(Vii) The interest charge made.urider this clause may be reduced under the prOcedures prescribed in 32.608
f of the Federal Acquisition Regulation in effect on the date of this contract.
Ul Risk of lOSS. Unless the contract specffically pro~des otherwise, nsk of loss or damage 10 the supplies
provided under this contract shall remain with the Contractor until, and shall pass to the Govemment upon:
(1) Delivery of the supplies to a carrier, if transportation is f.o.b. ongin; or
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293
(2) Delivery of the supplies to the Govemment at the destination specified in the contract, if transportation is
to.b. destination,
(k) Taxes. The contract price includes all applica~e Federal, State, and local taxes and duties.
(I) Termination for the Government's convenience. The Government reserves the right to terminate this contract,
or any part hereof, for its scle convenience. In the event of such termination, the Contractor shall immediately stop all
work hereunder and shall immediately cause any and all of its supplier; and subcontractor; to cease work. Subject to
the terms of this contract, the Contractor shall be paid a percentage of the contract price reflecting the percentage of
the work performed prior to the notice of tetminatidn, plus r~asonab[e charges the Contractor ,can demonstrate to the
satisfaction of the Government using its standard record keeping system, have resuHed from the termination. The
Contractor shall nol be required 10 comply with the cost acoounting standards or contract cost principles for this
purpose. This paragraph does not give the Government any Hght to audit the Contractors records. The Contractor
shall nol be paid for any work pe.rformed or costs incurred which reasonably could have been avoided.
(m) Termination for cause. The Government may' terminate this contract, or any part hereof, for cause in the
event of any default by the Contractor, or if the Contractor fails to comply with any contract terms and conditions, or
fails to provide the Government, upon request, with adequate assurances of future pertormance. In the event of
termination for cause, the Government shaH not be liable to the Contractor for any amOunt for supplies or ,seNices not
accepted, and the Contractor shall be liable to the Govemment for any and all rights and remedies provided by law. ~
it is determined that the Government imprope~y terminated thi.s contract for default, such termination shall be deemed
a termination for convenience.
(n) rille. Unless specified elsewhere in this contract, title to items fumished under this contract shall pass to the
Government upon acceptance, regardless of when or where the Government takes physical possession.
(0) Warranty. The Contractor warrants and implies that the items delivered hereunder are merchantable and frt
for use for the particular purpose described in this contract.
(p) Umftation of liability. Except as othei'Mse provided by an express warranty, the Conlractor will not be liable
to the Government for consequential damages resulting from any defect or deficiencie;g in accepted items.
(q) Other compliances. The Contractor shall comply with all applicable Federal, State and local laws, executive
orders, rules and regulations applicqble to its pertormance under this contract.
(r) Compliance wfth laws unique to Government contracts. The Contractor agrees to comply with 31 U.S.C. 1352
relating to limitations on the use of appropriated funds to influence certain Federal contracts; 18 U.S.C. 431 relating 10
officials notto benefit; 40 U.S.C. 3701 , et seq. , Contract Work Hour; and Safety Standards Act; 41 U.S.C. 51-58, AntiKickback Act of 1986; 41 U.S.C. 265 and 10 U.S.C. 2409 relating to whisheblower protections, 49 U.S.C. 40118, Fly
American; and 41 U.S.C. 423 relating to procurement integrity.
(s) Order of precedence. Any inconsistencies in this solicitation or contract shall be resolved by giving
precedence in the following order:
(1) The schedule of supplies/services.
(2) The ASSignments, Disputes, Payments, Invoice, Other Compliances, and Compliance with laws
Unique to Govemment Contracts paragraphs of this ciause.
(3) The clause at 52.212-5.
(4) Addenda to this solicitation or contract, including any license agreements for computer software.
(5) Solicitation provisions" this is a solicitation.
(6) Other paragraphs of this clause.
(7) The Standard Form 1449.
(8) other documents, exhibits, and ;lttachments.
(9) The specification.
(t) Central Contractor Registration (CCR).
(1) Unless exempted by an addendum to this contract, the Contractor is responsible during pertormance and
through final payment of any contract for the accuracy and completeness of the data within the CCR database, and for
any liability resulting from the Govemmenfs reliance on inaccurate or incomplete data. To remain registered inthe
CCR database after the initial registration, the Contractor is required to review and update on an annual basis from
the date of initial registration .or sub~equent updates ~s information in the CCR database to ensure it is current,
accurate and complete. Updating information in the CCR does not alter the terms and conditions of this contract and
is not a substiMe for a properly executed contractual document.
(2)0) If a Contractor has legally changed its business name, "doing business as" name, or division name
(whichever is Shown on the contract), or has transferred the assets used in pertorming the contract, but has not
completed the necessary requirements regarding novation and change-at-name agreements in FAR Subpart 42.12,
the Contractor shall provide the responsible Contracting Officer a minimum'of one business day's written notification
of its intention to (A) change the name in the CCR database; (8) comply with the requirements of Subpart 42.12; and
(C) agree in writing to the timeline and procedures specified by the responsible Contracting Officer. The Contractor
musl provide with the notification sutficient documentation to support the legally changed name.
Iii) If the Contractor fails 10 comply with the requirements of paragraph (t)(2)(i) of this clause, or fails to
pertorm the agreement at paragraph (t)(2)(i)(C) of this clause, and, in the.absence of a property executed novation or
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change-ofname agreement, the CCR infonnaiion that shows the Contractor to be other than the Contractor indicated
in the contract ";11 be considerad to be incorrect infonnation within the meaning of the ' Suspension of Paymenr
paragraph of the electronic funds transfer (EFI) clause of this contract.
(3) The Contractor shall not change the name or address for EFT payments or manual payments, as
appropnate, in the CCR record to reflect an assignee for the purpose of assignment afclaims (see Subpart 32.8,
Assignment of Claims). Assignees shall be sepatately registered in the CCR database.lnfonnation pro~ded to the
Contracto.!s CCR record that indicates payments, including those made by EFT, to an unimate recipient other than
that Contractor will be cpnsidered to be incorrect information within the meaning of the 'Suspension of payment"
paragraph of the EFT clause of this contract.
(4) Offerors and Contractors may obtain information on registration and annual confirmation
requirements ~a the intemet at hUp:/lWww.ccr.govorbycaliing 1-888-227"2423 or 26996.15757.

(End of Clause)
52.212-4 CONTRACTTERMS AND CONDITIONS - COMMERCIAL ITEMS (JUN 2010) ALTERNATE I (OCT 2008)
When atime-endmaterials or laborhour task orderis contemplated, the follo";ng paragraphs (a), (e), (i) and (I) shall
take precedence over those in the basic dause.
Aftemate I (Oct 200U). When a time-andmatenals or laborhour contract is contemplated, substitute the following
paragraphs (a), (e), (i) and (I) for those in the basic clause.
(a) Inspection/Acceptance. (1) The Govemment has the nght to inspect and test all matenals fumished and
services performed under this contract, to the extent practicable at all places and times, including the penod of
performance, and in any event before acceptance. The.Government may also inspect the plant or plants of the
Contractor or any subcontractor engaged in contract performance. The Government will perform inspections and tests
in a manner that will not unduly delay the work.
(2) If the Govemment perfonns inspection or tests on the premises of the Contractor or a subcontractor, the
Conilactor shall fumish and shall require subcontractors to fumish all reasonable facilnies and assistance for the safe
and convenient performance of these duties.
(3) Unless otherwise specified in the contract, the Govemment will accept or reject seNices and materials at the
place of delivery as promptly as practicable afier delivery, and they";l1 be presumed accepted 60 days afler the date
of delivery, unless accepted eanier.
(4) At any time dunng contract perfonn'nce, but not later than 6 months (or such other time as may be specified in
the contract) after acceptance of the selVices or materials last delivered under this contract, the Government may
require the Contractor to replace or correct services or matenals that at time of delivery failed to meet eontract
requirements. Except as otherwise specified in paragraph (a)(6) of this clause, the cost of replacement or correction
shall be determined under paragraph (i) of this clause,but the 'hourly rate' for labor hours incurred in the replacement
or correction shall be raduced to exclude that portion of the rate attrbutable to profit. Unless otherwiSe speened
below, the portion of the 'hourly rate' attnbutable to profit shall be 10 percent. The Contractor shall not tender for
acceptance materials and services required to be replaced or corrected without disclosing the former requirement for
replacement or correction, and, when required, shall disclose the corrective action taken.llnsert portion of labor rate
aftributable to profft]
(5)(i) If the Contractor fails to proceed ..;th reasonable promptness to perfonn required replacement or correction,
and if the replacement or correction can be performed within the ceiling price (or the ceiling price as increased by the
Govemment), the Govemment may(A) 8y contract or otherwise, perfonn the'replacement or correction, charge to the Contractor any increased
cost, or deduct such increased costirom any amounts paid or due under this contract; or
(8) Tenninate this contract for cause.
(ii) Failure to agree to the amount of increased cost to be charged to the Contractor shall be a dispute under
the Disputes clause of the contract.
(6) Notwithstanding paragraphs (a)(4) and (5) above, the Govemment may at any time require the Contractor to
remedy by correction or replacement, ";thout cost to the Govemment, any failure by the Contractor to comply wnh the
requirements of this contract, if the failure is due to-(i) Fraud, lack of good faith, or "; I ~I misconduct on the part of the Contracto!s managenal personnel; or
(ii) The conduct of one or more of the Contractor's employees selected or retained by the Contractor after 'any
0.1 the Contractor's managerial personnel has reasonable grounds to believe that the employee is habHually careless
or unqualified.
(7) This clause applies in the same manner and to the same extent to corrected or replacement materials or
selVices as to materials and selVices originally de.live~ under this contract
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(8) The Contractor has no obligation or liability unqer this contract to correct ot replace materials and services that
at time of delivery do not meet contract requirements, except as provided in this clause or as may be otherwise
specffied in the contract.
(9) Unless otherwise specified in the contract,the Contractols obligation to comect or replace Gbvemmentfurnished property shall be governed by the clause pertaining to Government property.
(e) Definaions. (1) The clause at FAR 52.202-1, Definitions, is incorporated herein by reference. As used in this
clause-~) Direct matenals means those materials that enter directly into the end product, or that are used or
consumed directiy in connection with the furnishing of the end product or seMce.
(ii) Hourly rate means the raters) prescribed inthe contract for payment for labor that meets the labor
category qualifications of a labor category specified in the contract that are(A) Pertorrned by the contra.ctor;
(8) Pertorrned by the subcontractors; or
(C) Transferred between divisions, subsidiaries, .or affiliates of the contractor under a common
control.
(iii) Materials means(A) Direct materials, induding supplies transferred between divisions, subsidiaries, or affiliates of the
contractor under a COmmon control;
(8) Subcontracts for supplies and in~dental services for which there is not a labor category specified
in the contract;
(0) Other direct costs (e.g. , incidental services for which there is not a labor category specified in the
contract, travel, computer usage charges, etc.);
(D) The following subcontracts for services which are specifically excluded fromthe houny rate:
[Insert any subconiracts for services to be excluded from the hourly rates prescribed in the schedule.l; and
(E) Indirect costs specifically pro~de<! for in this clause.
(iv) Subcontractineans any contract, as defined in FAR Subpart 2.1, entered into with a subcontractor to
furnish supplies or selvices for pertorrnance of the prime coniract or a subcontract induding transfers betw..n
divisions, subsidiaries, or affiliates of a contractor or subcontractor. It includes, but is not limited to, purchase orders,
and changes and modifications to purchase orders.
(i) Payments. (1) Services accepted. Payment shall be made for services accepted by the Government that
have been delivered to the delivery destination(s) set forth in this contract. The Govemment win pay the Contractor as
follows upon the submission of commercial invoices approved by the Contracting Officer:
(i) Hourly rate.
(A) The amounts shall be compUted by multiplying the appropriate houny rates prescribed in the
contract by the number of direct labor hours pertorrned. Fractional parts of an hoUr shall be payable
on a prorated basis.
(8) The rates shall be paid for all labor pertorrned on the cont",ct that meets the labor qualifications
specified in the contract. Labor hours incurred fo pertorrn tasks lor which labor qualifications were specified in
the contract will not be paid to the extent the work is pertormed by individuals that do not meet the
qualffications specffied in the contract, unless specifically authorized by the Contracting Officer.
(C) Invoices may be submitted once each month (or at more frequent intervals, ~ approved by the
Contracting Officer) to the Contracting Officer or the authorized representative.
(D) When roqueste<! by the Contracting Officer or the authorized representative, the Contractor shall
substantiate invoices (including any subcontractor hours reimbursed at the hourly rate in the sche<!ule) by
e~dence of actual payment, individual daily job timecards, records that verify the employ..s m..t the
qualifications for the labor categories specified in the contract, or other SUbstantiation specified in the
contract.
(E) Unless the Sche<!ule prescribes otherwise, the houny rates in the Schedule shall not be varied by
virtue of the c.ontractor having performed work on an overtime basis.
(1) If no overtime rates are pro~ded in the Sche<!ule and the Contracting Officer approves
overtime work in advance, overtime rates: shan be negotiated.
(2) Failure to agree upon these overtime rates shall be treated as a dispute under the
DispUtes dause of this contract
(3) If the Schedule pro~des rates for overtime, the premium portion 01 those rates will be
reimbursable only to the exient the overtime is approve<! by the Contracting Officer.
(ii) Materials.
(A) If the Contractor furnishes materials that meet the ~efinition 01 a commercial item at FAR
2.101, the price to be paid for such materials shall be the contl1lctols establiShed catalog or market
price, adjusted to reflectthe(1) Quantities being acquired; and
(2) Any modifications necessary because of contract requirements.
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(8) Except as prOvided for in paragraph (Q(I)0i)(A) and (D)(2) of this clause, the
Govemment will reimburse the Contractor the actual cost of materials (less any rebates, refunds, or
discounts received by the contractor that are identifiable to the contnlct) pro~ded the Contractor(1) Has made payments for materials in accordance with the lertns and conditions of the agreement or invoice; or
(2) Makes these payments ..;thin 30 days of the submission of the Contractors payment request to the
Government and $uch payment is in accordance with the terms and conditions of tile agreement or invoice.
(C) To the extent able; the Contractor shall-(1) Obtain malenals at the most advantageous pnces available I>ith due regard to
secunng prompt deliveiy of satisfactory matenals; and
(2) Give credIT to the Govemment for cash and trade discounts, rebates, scrap,
commissions, and other amounts U1at are identifiable to the contract.
(D) Other Costs. Unless listed below, other direct and indirect costs";l1 not be reimbursed.
(1) Other Direct Costs. The Govemment will reimburse the Contractor on the basis
of actual cost for the follo";ng, provided such costs comply with the requirements in paragraph (i)(l)(ii)(8) of this
clause: [Insert each element of other direct costs (e.g., travel, computer usage charges, etc. Insert -None"if no
reimbwsemenf for other direct costs will be provided. If this is an indefinfte delivery contract, the Contracting Officer
may insert 'Each order must list separatety the elements of o//Jer diract chargers) for that order or, if no
reimbursement for other direct costs will be provided, insert 'None'.1
(2) Indirect Costs (Maleria' Handling, Subconlract Administration, etc.). The
GQvetnment will reimburse the Contract.or for indirect costs on a pro-rata basis over the period of contr;;lct
performance at the following fixed price: [Insert a fixed amount for the Indirect costs and payment schedule. Insert ~$O~
if no fIXed price reimbursement for indirect costs will be provided. (ff this is an indefinite delivery contract, the
Conlracting Officer may insert "Each oirier must lisl separalely the fixed amounl for the indirect cosls and paymenl
schedule or, if no reimbursemenl for indirect costs, insert 'None).'
(2) Total cost. It is estimated that the total cost to the Govemment for the pertormance of this contract shall
not exceed the ceiling pnce set forth in the Schedule and the Contractor agrees to use ITS best efforts to pertorm the
work specified in the Schedule and all obligations under this contract within such ceiling price. If at any time the
Contractor h.as reason to believe that the hourly rate payments and matenal costs that";l1 accrue in pertorming this
contract in the next succeeding 30 days, if added to all other payments and costs previously accrued, ";11 exceed 85
pertent of the ceiling price in the Schedule, the Contractor shall notify the Contracting Officer giving a revised
estimate of the tolal pnce to the Govemment for perfOrming this contract with supporting reasons and documentation.
If at any time dunng the performance ot this contract, the Contractor has reason to believe that the total pnce to the
Govemment for performing this contract";l1 be substantially greater or less than the then stated ceiling pnce, the
Contractor shall so notify the Contracting Officer, giving a re~sed estimate of the total pnce for performing this
contract, with supporting reasons and documentation. If at any time during performance Of this contract, the
G.ovemment has reason to believe that the work to be required in performing this contract will be substantially greater
or less than the slated ceiling price, the Contnlcting Officer ";11so ad~se the Contractor, giving the then revised
estimate of the total amount of effort to be required under the contract.
(3) Ceiling price. The Govemment";l1 not be obligated to pay the Contractor any amount in excess of the
ceiling price in the Schedule, and the Contractor shall nOt be obligated to continue PerfQrmance if to do so would
exceed the ceiling pnce set forth in the Schedule, unless and until the Contracting Officer notifies the Contractor in
writing that the ceiling price has been increased and specifies in the notice a revised ceiling that shall constitute the
ceiling pnce for performance under this contract. When and to the extent that the ceiling pnce set forth in the Schedule
has been increased, any hours expended and material costs incurred by the Contractor in excess of the ceiling price
before the increase shall be allowable to the same extent as IT the hours expended and material costs had been
incurred after the increase in the ceiling price.
(4) Access 10 racords. At any time before final payment under this contract, the Contracting Officer (or
auttlorized representative) Will have access to the following (access s.hall be limited to the listing below unless
olherwise agreed to by the Contractor and the Contracting Officer):
(i) Records that verily that the employees ..;hose time has been included in any invoice meet the
qualffications for the labor categones specffed in the COntract;
0i) For labor hours (including any subcontractor hours reimbursed at the hourly rate in the schedule),
when timecards are required as substantiationfor payment(A) The onginal timecards (paper-based or electronic);
(8) The Contractors timekeeping procedures;
(C) Contractor records that show the distributio.n of labor between jobs or contracts; and
(D) Employees whose time has been included in any invoice for the purpose of venfying that
these employ_
ees have worked the hours shown on the invoices.
(iiij For material and subcontract cQsts that are reimbursed on the b?lsis of actual cost(A) Any invoices or subcontract agreements substantiating matenal costs; and
(8) Any documents supporting payment of those invoices.
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(5) OverpaymentslUnderpayments. Each payment previously made shall be subject to reduction to the ex/ent
of amounts, on preceding invoices, that are found by the Contracting Officer not to have been properly payable and
shall also be subject to reduction for overpayments or to increase for underpayments. The Contractor shall promptly
pay any such reduction within 30 days unless the parties agree otherwise. The Govemment within 30 days will pay
afiy such increases, unless the parties agree otherwiSe. The Contractors payment will be made by check. If the
Contractor becomes aware of a duplicate invoice payment or that the Government has otherwise overpaid on an
invoice payment, the Contractor shall(i) Remit the overpayment amount to the payment office cited in the contract along with a description
of the overpayment including the(A) Circumstances of the overpayment (e.g., duplicete payment, erroneous payment, liquidation errors, date(s) of
overpayment);
(8) Affected contract number and delivery order number, if appliceble;
(C) Affected contract line item or subline nem, if applicable; and
(0) Contractor point of conlact.
Oi) Provide a copy of the remittance and supporting documentation to the Contracting Offcer.
(6)(i) All amounts that become payable by the Contflict,or to the Government under this contract shall bear
simple interest from the date due until paid unless paid within 30 days of becoming due. The interest rale shall be the
interest rate established by the Secretary of the Treasury, as provided in section 611 of the Contract Disputes Act of
1978 (Public Law 95-563), which is.applicable to the penad in which the amount becomes due, and then at the rate
applicable for each siX month penod as eslablished by the Secretary until the amount is paid.
(ii) The Govemmenl may issue a demand for payment to the Contractor upon finding a debt is due under
thecontract.
Oii) Final Decisions. The Contracting Offcer";l1 issue a final decision as required by 33.211 if(A) The Contracting Offcer and the Contractor are unable to reach agreement on the existence .or amo.unt of a debt in
a timely manner,
(8) The Contra.ctor fails to liquidate a debt previously demanded by the Contracting Offcer ..;thin the timeline
specifi.ed in the demand fOf payment unless the amounts were not repaid because the Contractor has requested an
installment payment agreement; or
(C) The Contractor requests a deferment of collection on a debt previously demanded by the Contracting Offcer (see
FAR 32.607-2).
(iv) If a demand for payment was previously ISSUed for the debt, the demand for payment included in the
final decision shall identify the same due date as the original demand for payment.
(v) Amounts shall be due at the earliest of the follo";ng dates:

(A) The date fixed under this contract.
(8) The date of the first wntten demand for payment, including any demand for payment resulting from a defautt
tetmination.
(vi) The interest charge shall be computed for the actual number of calendar days involved beginning on the
due date and ending on(A) The date on which the deSignated office receives payment from the Conlractor,
(8) The date of issuance of a Government check to the Contractor from which an amount otherwise payable has been
withheld as a credit against the contract debt; or
(C) The date on which an amount ..;thheld and applied to the contract debt would otherwise have become payable 10
the Contractor.
(vii) The ihterest Charge made under this clause may be reduced under the procedures prescribed in
32.608-2 of the Federal AcqUisition RegulatiOll in effect on the date of this contract.
(viii) Upon receipt and approval of the invoice designated by the Contractor as the 'completion invoice' and
supporting documentation, and upon compliance by the Contractor..;th all terms of this contract, any outstanding
baiances will be paid within 30 days unless the parties agree otherwise. The completion invoice, and supporting
documentation, shall be submitted by the Contractor as promptly as practicable follo";ng completion of the wor!<
under this contract, but in no event later than 1 year.(or such longer penod as the Contracting Officer may approve in
wnting) from the date of completion.
(7) Release orc/aims. The Contractor, and each a"ssignee under an assignment entered into under this
contract and in effect at the time of final payment under this contract, shall execute and deliver, at the time of and as a
condition precedent to final payment under this contracl, a release discharging the Government, its officers, agents,
and employees of and from all liabilities, obligations; and claims ariSing out of or under this contract, subject only to
the following exceptions.
0) Specified claims in slated amounts, or in estimated amounts if the amounts are not susceptible to
exact statement by the Contractor.

(ii) Claims, together with reasonable incidental expenses, based upon the liabilities of the Contractor
to third parties ansing out of pertorrning this contract, that are not known to the Contractor on the date of the
execution of the release, and of which the Contractor gives notice in wnting to the Contracting Offcer not
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more tIlan 6 years after the date of the release or the date of any notice to the Contractor that the
Government is prepared to mak~ final payment, whichever is eanier.
~ii) Claims for reimbursement of costs (other than expenses of the Contractor by reason of its
indemnification of the Govemment against patent liability), including re_asonable inad.ental expenses, incurred
by the Contractor under tile tenns of this contract relating to patents.
(8) Prompt payment. The Government will make payment in accordarn:e witll tile Prompt Payment Act
(31 U.S.C. 3903) and prompt payment regulations at 5 CFR part 1315.
(9) Eleelronic Funds Transfer (EFT). Ifthe Government makes payment by EFT, see 52.212-5(b) for tile
appropnate EFT clause.
(10) Discount. In connection witll any discount offered for early payment, time shall be computed ~om tile
date of the invoice: For the purpose of computing the discouht earned, payment shall be considered to have been
made on the date that appears on the payment check or the specified payment date if an electronic funds transfer
payment is made.
(I) Termination forthe Government's convenience. The Government reserves the nght to tenninate tIlis contract, or
any part hereof, fot its .50.1e convenience. In the event of such termination, the Contra~or shall immediately _
stop all
work hereunder and shall immediately cauSe any and all of its suppliers and subcontractors to cease work. Subject to
the terms of this contract, the Contractor shall be paid an amount for direct labor hours (as defined in the Schedule of
tile contract) determined by multiplying the number of direct labor hours expended before the effective date of
tennination by the hourty rate(s) in the contract, less any hourly rate payments already made to the Contractor plus
reasonable charges the Contractor can demonstrafe to the satisfaction of the Government using its standard record
keeping system that have resultedfrom the termination. The Contractor shall not be required to comply with the cost
aocounting standards or contract cost pnnoples for this purpose. This paragtaph does not give the Govemment any
nght to audit the Contractors records. The Contractor shall not be paid for any work pertonned or costs incurred that
reasonably could have been avoided.
ADDENDUM TO 52.212-4, CONTRACT TERMS AND CONDITIONS - COMMERCIAL ITEMS (JUN 2010)
INVOICES
Invoices shall be submitted electronically to the e-mail address shown in Block 18a, page 1 of award. Protected
Microsoft Excel files are tile preferred format; however, Adobe Acrobat Portable Document Format (PDF) and
Microsoft Word are also aoceptable
PAYMENT INFORMATION:
Receive a free email notice of your electronic payment. Register at WYM'jpp.gov.
OVERPAYMENTS
In accordance with 52.212-4 section (i) 5 Overpayments: Accounts Receivable Conversion of Check Payments to
EFT: If tile Contractor sends the ~overnment a check to remedy duplicate contract financing or an overpayment by
the government, it will be converted into an electronic funds transfer (EFT).This means ihe Governmeni will copy tile
check and use tile account infonnation on it to electronically debit tile Contractors account for the amount of tile
check. The debn from the Contrador's account will usually occur within 24 hours and will be shown on the regular
account statement
The Contractor will not receive the original check back. The Government will destroy the Contractor's o'riginal check,
but will keep a copy of n. If the EFT cannot be processed for technical reasons, the Contractor authorizes the
Govemment to process the copy in place of the original check.
MARKING OF SHIPMENTS:
Please ensure that tile contract number (Block 2) is clearly visible on all shipping/service documents, containers, and
invoices.
1052.201-70 CONTRACTING OFFICER'STECHNICAL REPRESENTATIVE (COTH) APPOINTMENT AND
ALITliORllY (APR 2004) (DEVIATION) (DTAR)
a. The Contracting Officers Technical Representative(s) is listed on page 2 of award.
b. Perfofrtlance of work under this contract must be subject to the technical direction of the COTR identified above, or
a representative designated in writing. The tenn "technical direction" includes, without limitation, direction to the
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contractor Ihal directs or redirects the labor effort, shifts the work between work areas or locations, fills in delails and
olherwise selVes 10 ens.ure thai tasks outlined in the work slalemenl are aooomplished salisfactorily.
c. Technical directon must be v.ill1in the scope of the spectfication(s)lwork stalement. The COTR does nol have
authority to issue technical direction that:
1. constitutes a change of assignmenl or additional work outside the specffication(s)/work slalemen\
2. constitutes a change as defined in the clause titled 'Changes';
3. in any manner causes an increase or decrease in the contract price, or the time required for contract
perlormance;
4. changes any of the lerms, conditions, or specification(s)lwork slalemeni of the conlract;
5. interferes with the Contractor's right to perfonn under the terms and conditions of the contract; or
6. directs, supelVises or otherwise controls Ihe actions of the contractors employees.
d. Technical directon may be oral or in wriling. The COTR shall confirm oral direction in writing v.1thin fwe workdays,
v.ill1 a copy 10 the contracting officer.
.
e. The contractor shall proceed promptly v.1th perlonnance resulling from the lechnical directon issued by Ihe COTR.
ff, in the opinion of the contractor, any direction of the COTR, or hislher designee, falls v.ill1in Ihe limnalions in (c)
above, the contractor shall immedialely notify the contracting officer no laler than the begiming of the next
Govemmenl work day.
f. Failure of the contractor and the contracting officer to agree that technical direction is within the scope of the
coniraci shall be subject 10 the lerms of the clause titled 'Dispules.'
52.213-2 Invoice, (April 1984)

In accordance with the above clause the contractor shall invoice at the beginning of the service period for the entire
period.
52.216-18 ORDERING (OCT 1995)
(a) Any supplies and services 10 be fumished under Ihis contract shall be ordered by issuance of delivery
orders or task orders by the individuals or activities design~ed in the Schedule. Such orders may be issued from
09/30111 Ihrough 09129116.
(b) All delivery orders or lask orders are subject 10. the term, and conditions of this contract. In the evenl of
conflict between a delivery order or task order and this contract, the contract shall control.
(c) If mailed, a delivery order or task order is considered "issued"when the Government depos~s the order in
lhe mail. Orders may be issued orally, by facsimile, or by electronic commeroe methods only ~ authorized in the
Schedule.
52.216-19 ORDER LIMITATIONS (OCT 1995)

(a) Minimum order. When the Government requires supplies or services covered by this contract in an
amounl of less Ihan $24,000.00, the Govemmenl is nol obligaled 10 purchase, nor is Ihe Contractor obligaled 10
fumish, those supplies or services under Ihe contract.
(b) Maximum orde, The Contractor is nol obligaled 10 honor(1) Any order for a single nem in excess of $1,645,000.00;
(2) Any order for a combination of nems in excess 018,379,000.00; Of
(3) A series of orders from tha same ordenng office v.1Ihin 30 days thai logether call for quantilies exceeding
the limitation in paragraph (b)(I) or (2) of thiS section.
(c) If this is a requirements contract (i.e., includes the Requiremenls dause al subsecton 52.216-21 of the
Federal Acquisition Regulation (FAR)), the Govemmenl is nol required 10 order a part of anyone requirement from Ihe
Contractor if that requirement exceeds the maximum-ordj"lr limitqtions in paraglilph (b) of this section.
(d) Notwfihslanding paragraphs (b) and (c) of this seclion, the Conlraclor shall honor any order exceeding the
maximum order limnations in paragraph (b), unless Ihal order (or orders) is relumed 10 Ihe ordenng offioe within 10
days after issuance, v.ill1 writien notice stating the Contractors inlenl nollo ship the nem (or nems) called for and the
reasons. Upon recaJ~ng this notice, the Govemmenl may acquire the supplies or services firom another souroe.
52.216-20 INDEFINITE QUANTTTY (OCT 1995)
(a) This is an indefinile-quanlify contract fot the supplies or services specified, and effective for the penod
slaled, in the Schedule. The quantities of supplies and services spec~ed in Ihe Schedule are estimates only and are
nol purchased by this contracl.
(b) DeliVery or perlormance shall be made only as authorized by orders issued in acoordance v.1th the
Ordering dause. The Contractor shall fumish 10 the Govemmenl, when and ~ ordered, the supplies or selVices
spec~ed in the Schedule up 10 and including tha quantify designaled in the Schedule as the 'maximum.' The
Government shall order at least the quantity of supplies or services designated in the Schedule as the minimum.
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(c) Except for aoy lim,ations on quantities in the Order limitations clause or in the Schedule, there is no limit
on the number of orders thq:i may be i.ssued. The Gov,emmenl may issue orders requiring delivery to ml,lltiple
destinations or performance at multiple locations.
(il) Any order issued during the effective period of this contract and not completed within that period shall be
completed by the Contractor within the time specified in the order. The contract shall govern the Contractors and
Govemment's rights and obligations with raspect to that order to the same eident as IT the order were completed
during the contract's effective period; provided, that the Contractor shall not be required to make any deliveries under
this contract after 9129/16.
52.2t7-8 OPTION TO EXTEND SERVICE (NOV 1999)
The Government may require continued performance of any services-within the limits and at the rates specified in the
contract. These rates may be adjusted only as a result of revisionS to prevailing labOr rates provided by the Secretary
of Labor, The option provision may be exercised more than once, but the total extension of pertormance hereunder
shall not exceed 6 months. The Contracting Officer may exercise the option by written notice to the Contractor within
30 days before the contract expiration date.
52.217-9 OPTION TO EXTEND THE TERM OF THE CONTRACT (MAR 2000)
(a) The Govemment may eidend the tenn of this contract by written notice to the Contractor within the final
30 days of each contract period; provided, that the Government gives the Contractor a preliminary written notice of its
intent to extend at least 30 days ~fore the contract expires. The preliminary notice does not commit the Gov~mment
to an extension.
(b) If the Govemment exercises this option, the eidended contract shall be considered to include this option
clause.
(c) The total duration of this contract, including the exercise of any options under this clause, shall not
exceed 60 months.
CONTRACT TERM
The period of perfohTlance for this procurement is a Base Period of 12 months and four 12-month Option Periods.
CONTRACT MINIMUM AND MAXIMUM

(~) The minimum amourit the Government is obligated to order during the term of the contract is
$154,000.00.
(b) The maximum amount of the contract will be $8,379,000.00.
PERFORMANCE EVALUATION
This contract is subject to a pertonnance evaluation. Following the end of the rontract period, a completed
GQvernment evaluatiQn shall be forwarded to the Cootractor. The Contractor may sublll' written comments, if any,
within the time period specified in the evaluation transmittal. The Contractor's comments shall be considered in the
issuance Qf the final evaluation document. Any disagreement between the parties regarding the evaluation shall be
forwarded to the Bureau Chief Procurement Officer (BCPO). The final evaluation of the Contractors perfonilance is
the decision of the BCPO. A copy of the final pertonnance evaluation report will be sent to the Contractor and to the
Govemment'.s past performance database at www.ppirs.gov.
PUBLIC-RELEASE OF CONTRACT VERSION REQUIREMENT

Wrthin 10 business days of award, the contractor shall submit to the COTR a .pdf file of the fully executed contract or
task order with all proposed necessary redactions, including redactions of any trade secrets or any commercial or
financial information that it believes to be privileged or confidential business information, for the purpose of public
disclosure at the sole discretion of the Government The contractor shall provide a detailed written statement
specifying the basis for each of its proposed redactions, including the applicable exemption under the Freedom of
InfOI111a1ion Act (FOIA), 5 U.S.C. 552, and, in the case of FOIA Exemption 4,5 U.S.C. 552(b)(4), shall
demonstrate why the information is considered to be a trade secret or commercial or financial information that is
pri~leged or confidential. Infonnation provided by the contractor in response to this requirement may nse~ be subject
to disclosure under the F01A
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The Government ",II carefully consider all of the contractor's proposed redactions and assadated grounds for
nondisdosure prior to ma~ng a final detenninatiOll as to what infonnation in the fully executed contract may be
prope~y \IOthheld.
52.212-5
CONTRACT TERMS AND CONDITIONS REQUIRED TO IMPLEMENT STATUTES OR

EXECUTIVE ORDERS -COMMERCIAL ITIEMS (AUG 2011)
(a) The Contractor shall comply wtth the follo\\Ong Federal Acquisition Regulation (FAR) dauses. which are
incorporated in this contract by re'ference, to implement provisions of law or Executive orders applicable to
acquisitions of commercial items:
(1) 52.222-50, Combating Trafficking in Persons (Feb 2009) (22 U.S.C. 7104lgH.
_ Attemate I (Aug 2007) of 52.222-50 (22 U.S.C. 7104(gH.
(2) 52.233-3 Protest Aft., Award (AUG 1996)(31 U.S.C. 3553).
(3) 52.233-4, Applicable Law for Breach of Cootract Claim (DeT 2004) (Pub.l. 108-77, 108-78)
(b) The Contractor shall comply \10th the FAR dauses in this paragraph (b) that the Contracting Officer has
indicated as being incorporated in this contract by reference to implement pro~sions of law or Executive orders
appUcab)e to aQquisitions of commercial items:
_X_ (1) 52.203-5, RestJictions on Subcontractor Sales to the Govemment(Sept 2006), "'th Alternate I
(Oct 1995) (41 U.S.C. 253g and 10 U.S.C. 2402).
_ (2) 52.203-13 Contractor Code of Business Ethics and Conduct (Apr 2010) (Pub.l. 110-252, T~e VI.
Chapter 1 (41 U.S.C. 251 note)).
_ (3) 52.203-1.5 Whistleblower Protections under the American Recovery and Reinvestment Act of 2009
(June 2010) (Section 1553 of Pub. L. 111-5). (Applies to contracts funded by the American Recovery and
Reinvestment Act of 2009.)
_X_ (4) 52.204-10, RepOrting Executive Compensation and First-TIer Subcontract Awards (JuI2010) (Pub.l.
109'282) (31 U.S.C. 6101 note).
_ (5) 52.204-11 American Recovery and Reinvestment Act-Reporting ReqUirements (JuI2010) (Pub. L.
111-5).
_X_ (6) 52.209-6 Protecting the Govemmenfs Intere.st When Subcontracting \10th Contractors Debarred,
Suspended. or Proposed for'Debannenl (Dec 2010) (31 U.S.C.- 6101 note).
_ (7) 52.209-10, Prohibition on Contracting "'th Inverted Domestic Corporations (section 740 of DivisiOll C
of Pub. l. 111 -1 17, section 743 of Division 0 of Pub. l. 111-8, and section 745 of Division 0 of Pub. l. 110-161).
_ (8) 52.219-3, Notice ofTotal HUBZone Set-Aside or Sole-Source Award (Jan 2011) (15 U.S.C. 657a) ..
_ (9) 52.219-4, Notice of Price Evaluation Preference for HUBZOIle Small Business Concerns (JAN 2011) (ff
the offeror elects to waive the preference, tt shall so indicale in tts offer) (15 U.S.C. 657a).
_ (10) [Reserved]
_ (11)0) 52.219-6, Notice ofTotal Small Business Set-Aside (JuneZ003) (15 U.S.C. 644).
_0i) Alternate I (Oct 1995) of 52.219-6.
_ (iii) Alternate II (Mar 2004) of 52.219-6 _
_ (12)0) 52.219-7, Notice of Partial Small Bu~ness Set-Aside (June 2003) (15 U.S.C. 644),
_ 0i)Altemate I (Oct 1995) of 52.219-7.
_ (iii) .AJtemate II (Mar 2004) of 52.219-7.
_X_ (13) 52.219-8, Utilization of Small Business Concerns (Jan 2011) (15 U.S.C. 6371dH2) and (3)).
_X_ (14)(i) 52.219-9. Small Business Subcontracting Plan (Jan 2011) (15 U.S.C. 637IdH4)).
_ 0i)AKemate I (Oct 2001) of 52.219-9.
_ (iii) Alternate II (Oct 2001) of 52.219-9.
_ (iv) AIIemaie III (JuI2010) of 52.219-9.
_ (15) 52.219-14, Limttations OIl Subcontracting (Dec 1996) (15 U.S.C. 637(a)114)).
_X_ (16) 52.219-16, Liquidated Damages-Subcon-lracting Plan (Jan 1999) (15 U.S.C. 637(d)14HFlOl).
_ (17)(i) 52.219-23, Notice of Price Evaluation Adjustment for Small Disadvantaged Business Concerns
(OCT 2008) (10 U.S.C. 2323) (if the offeror elects to waive the adjustment, tt shall so indicate in tts offer).
_ (ii) Alternate I (June 2003) of 52.219-23,
_X_ (18) 52.219-25, Small Disadvanlaged Business Participation Program-Disadvantaged Status and
Reporting (Dec 2010) (pub. L. 103-355, section 7102, and 10 U.S.C. 2323).
_X_(19) 52.219-26, Small Disadvanlaged Business Participation Program-Incentive Subcontracting
(Oct 2000) (Pub. L 103-355, section 7102, and 10 U.S.C. 2323).
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_ (20) 52.219-27, Notice oITotal Service-Disabled Veteran-OWned Small Business Set-Aside (May 2004)
(15 U.S.C. 657 O.
_X_ (21) .52.219-28, Post Award Small Business Progmm Rerepresentation (Apr 2009) (15 U.S.C.
632Ial(21).
_ (22) 52.219-29 Notice cfTotal Set-Aside for Economically Disadvantaged Women-Owned Small Business
(EDWOSB) Concerns (Apr 2011).
_ (23) 52.219-30 Notice oITotal Set-Aside for Women-OWned Small Business (WOSS) Concerns Eligible
Under the WOSB Progmm (Apr 2011).
_X_ (24) 52.222-3, Convict Labor (June 2003) (E.O. 11755).
_X_ (25) 52.222-19, Child Labor-Cooperation with Authorities and Remedies (JuI2010) (E.O. 13126).
_X_ (26) 52.222-21 , Prohibition of Segregated Fadlities (Feb 1999).
_X_ (27) 52.222-26, Equal Opportunity (Mar 2007) (E.O. 11246).
_X_ (28) 52.222-35, Equal Opportunity for Velerans (Sep 2010)(38 U.S.C. 4212).
_X_ (29) 52.222-36, Aflinnative Action for Workers with Disabilities (Oct 2010) (29 U.S.C. 793),
_X_ (30) 52.222-37, EmploymenlReports on Veterans (SEP2010) (38 U.S.C. 4212).
_X_ (31) 52.222-40, Notification of Employee Rights Under Ihe National Labor Relations Act (Dec 2010)
(E.O. 13496).
_ (32) 52.222-54, Employment Eligibility Verification (JAN 2009). (Executive Order 12989). (Not applicable to
the acquisition of commercially available off-the-shelf items or certain other types of commercial items as prescribed in
22.1803.)
_ (33)(i) 52.223-9, Estimate of Percentage of Recovered Materi.al Content for EPA-Oesignated Items
(May 2008) (42 U.S.C. 6962{cl{3I{AlIiil). (Not applicable to Ihe acquisition of commercially available off-the-shen
items.)
_ (ii) Altemale I (May 2008) of 52.223-9 (42 U.S.C. 6962{ill2l1CI). (Not applicable to the acquisnion of commerdal~
available off-the-shen items.)
_ (34) 52.223-15, Energy Effidency in Energy-Consuming Products (DEC 2007) (42 U.S.C. 8259b).
_ (35)(i) 52.223-16, IEEE 1680 Standard for the Environmenlal Assessment of Personal Computer
Products (DEC 2007) (E.O. 13423).
_ (ii) Memale I (DEC 2007) of 52.223-16.
_X_ (36) 52.223-18 Encouraging Conlractor Policies to Ban Text Messaging While Dnving (AUG 2011) (E.O.
13513).
_ (37) 52.225-1 , Buy Amencan Act-Supplies (Feb 2009) (41 U.S.C. 10a-1Od).
_ (38)(i) 52.225-3, Buy Amencan Act-Free Trade Agreements-Ismeli Trade Act (June 2009)
(41 U.S.C. 10a-l0d 19 U.S.C. 3301 note, 19 U.S.C. 2112 note, 19 U.S.C ..3B05 note, Pub. L. 108-77, 108-78, 108286,108-302,109-53, 109-169,109-283, and 110-138).
_ (ii) Memate I (Jan 2004) of 52.225-3.
_ (iii) Memate II (Jan 2004) of 52.225-3.
_ (39) 52.225-5, Trade Agreements (AUG 2009) (19 U.S.C. 2501 ef seq., 19 U.S.C. 3301 note).
_X_ (40) 52.225-13, Restrictions on Cert.ain Foreign Purchases (June 2008) (E.O.'s, proclamations, and
statules adminiSlered by the Office of Foreign Assets Control of the Department of the Treasury).
_ (41) 52.226-4, Notice of Disaster OJ Emergency Area Set-Aside (Nov 2007) (42 U.S.C. 5150).
_ (42) 52.226-5, Restrictions on Subcontracting Outside Disaster or Emergency Area (Nov 2007) (42 U.S.C.
_ (43) 52.232-29, Terms for FinanCing of Purchases of COmmeraalltems (Feb 2002) (41 U.S.C. 255(0,
10 U.S.C. 2307(0).
_(44) 52.232-30, Installment Payments for Commerdalltems (Oct 1995) (41 U.S.C. 255(0,
10 U.S.C. 2307(0).
_X_ (45) 52.232-33, Paymenl by Electronic Funds Transfer-Central Contraclor Registration (Oct 2003)
(31 U.S.C. 3332).
_ (46) 52.232-34, Payment by Electronic Funds Transfer-Other Ihan Central Contractor Registration
(May 1999) (31 U.S.C. 3332).
_ (47) 52.23236, Payment by Third Party (Feb 2010)(31 U.S.C. 33321.
_ (48) 52.239-1, Privacy or secunty Safeguards (Aug 1996) (5 U.S.C. 552al.
_ (49)(Q 52.247-64, Preference for Pnvalely Owned U.S.-Flag Commercial Vessels (Feb 2006)
(46 U.S.C. Apox. 1241{bl and 10 U.S.C. 2631).
_ (ii) Allemate I (Apr 2003) 0152.247-64.
(c) The Contractor shall comp~ with the FAR dauses in this pamgmph (c), applicable to commercial
services, that the Contracting Officer has indicated as being incorporated in this contract by reference to implement
provisions of law or Executive orders applicable to acqUisitions of commercial items:
_ (1) 52.222-41, Service ConlractActof 1965, (Nov 2007) (41 U.S.C. 351 , ef s~q.).
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_ (2) 52.222-42, Statement of Equivalent Rates for Federal Hires (May 1989) (29 U.S.C. 206 and
41 U.S.C. 351 , elseq.).
_ (3) 52.222-43, Fair Labor Standards Act and Service Contract Act-Pnce Adjustment (Multiple Year and
Option Contracts) (Sep 2009) (29 U.S.C. 206 and 41 U.S.C. 351 el seq.).
_ (4) 52.222-44 Fair Labor Siandards Act and Service Contract Act-Pnce Adjustment (Sep 2009)
(29 U.S.C. 206 and 41 U.S.C. 351 el seq,).
_ (5) 52.22251 Exemption from Application of the Service Contract Act to Contracts lor Maintenance,
Calibration, or Repairaf Certain Equipment-Requiremenis (Nov 2007) (41 U.S.C. 351, el seq.).
_ (6) 52.22253 Exemption from APplication of the Service Contract Act to Contracts for Certain ServicesRequirements (Feb 2009) (41 U.S.C. 351, el seq.).
_ (7) 52.226-6 Promoting Excess Food Donation to Nonprofit Organizations (Mar 2009) (Pub. L. 110-247).
_ (8) 52.23711 , Accepting and Dispensing of 51 Coin (Sept 2008) (31 U.S.C. 5112(p)(1I).
(d) Complroller General Examination of Record. The Contractor shall comply with the provisions of this
paragraph (d) ~ th~ contract was awarded using other than sealed bid, is in excess of the simplffied acquisition
threshold, and does not contain the clause at 52.215-2, Audn and Records-Negotiation.
(1) The Comptroller General of the United States, or an authonzed representative of the Comptroller General,
shall have access to and righl to examine any of the Contractor's directl)i pertineht records invoMng transactions
relaled to this contract.
(2) The Contractor .shall mak.e available at its offices at all reasonable times the records, materials, and other
evidence for examination, audn, or reproduction, until 3 years after final payment under this contract or for any shorter
period specffied in FAR Subpart 4.7, Contractor Records Retention, of the other clauses of this contract. If this
contract is complete~ or partially terminated, the records relating to the wor!< terminated shall be made available for
3 years after any resulting fihallermination settlement. Records relaling to appeals under the disputes clause or to
litigation or the settlement of claims ansing under or relating to this contract shall be made available until such
appeals, litigation, or daims are finally resolved.
(3) As used in this clause, records include books, documents, accounting procedures and practices, and
other data, regardless of type and regardless of fann. This does not require the Contractor to create or maintain any
record thai the Contractor does not maintain in the ordinary course of business or pursuant to a provision of law.
(e)(1) Notwithstanding the requirements of the dauses i~ paragraphs (a), (b), (c), and (d) 9f this clause, the
Contractor is not required to flow down any FAR clause, other than those in paragraphs (e)(1)(i) through (xi) of this
paragraph in a subcontract for oommerdal items. Unless otherwise indicated below, the extent of the flow down shall
be as required by the clause(0)52.203-13 Contractor Code of Bu~ness Ethics and Conduct (APr 2010) (Pub. L. 110252, Trtle VI,
Chapter 1 (41 U.S.C. 251 note)).
Oij 52.219-8 Utilization of Small Business Concerns (Dec 2010) (15 U.S.C. 637(dll2) and (3)), in all
subcontracts that offer further subcontracting opportunities. If the subcontract (except subcontracts to small business
ooncems) exceeds $650,000 ($1.5 million for construction of any public fadlity), the subcontractor must include
52.219-8 in lower tier subcontracts that offer subcontracting opportunities.
(iiij(Reserved)
(iv) 52.22226 Eqyal Opportunity (Mar 2007) (E.O. 11246).
(v) 52.22235, Equal Opportunny for Veterans (Sep 2010) (38 U.S.C. 4212).
(vi) 52.22236, Affirma~ve Action forWor!<ers with Disabilities (Oct 2010) (29 U.S.C. 793).
(vii) 52.222-40, Notification of Employee Rights Under th~ National La~or Rel.ations Act (Dec 2010) (E.O.
13496). Flow down required in accordance with paragraph (Q of FAR clause 52.222-40.
(viii) 52.222-41 Service Contract Act of 1965 (Nov 2007) (41 U.S.C. 351 el seq.).
(ix) 52.22250, Combating Trafficl<ing in Persons (Feb 2009) (22 U.S.C. 7104(9)).
_Alternate I (Aug 2007) of 52.22250 (22 U.S.C. 7104(g)).
(x) 52.22251 Exemption from Application of the Service Contract Act to Contracis for Maintenance,
Calibration, or Repair of Certain EquipmentRequirements (Nov 2007) (41 U.S.C. 351 el seq.).
(xi) 52.22253 Exemption from Application of the Service Contract Act to Contracts for Certain ServicesRequirements (Feb 2009) (41 U.S.C. 351 el seq.).
(xii) 52.22254, Employment E1igibilny Vertfication (JAN 2009).
(xiiij 52.226-6 Promoting Excess Food Donation to Nonprofit Organ~ations (Mar 2009) (pub. L 11()-247).
Flow down required in accord.ance with paragraph (e) of FAR clause 52.226-6.
(xiv) 52.247-64 Preference for Pnvately Owned U.S.Flag Commerdal Vessels (Feb 2006) (46 U.S.C.
APpx. 1241(b) and 10 U.S.C. 2631). Flow down required in accordance with paragraph (d) of FAR
clause 52.247-64.
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(2)While not required, the contractor may include in its subcontracts for commercial items a minimal number
of additional dauses necessary to satisfy's contractual obligations.
Alternate / (Feb 2000). As preSClibed in 12.301(b)(4W), delete paragraph (d) from the basic dause, redesignate
paragraph (e) 'as paragraph (d), and re~se the reference to ' paragraphs (a), (b), (c), or (d) of this clause' in the
redeSignated paragraph (d) to read ' paragraphs (a), (b), and (c) of this clause'.
Alternate 1/ (Dec 2010). As prescribed in 12.301(b)(4)(ii), substitute the follo';ng paragraphs (d)(I) and (e)(l) for
paragraphs (d)(l) and (e)(l) of the basic clause as follows:
(d)(l) The Comp~oller General of the United States, an appropriate Inspector General appOinted under section 3 or
8G of the Inspector General Act of 1978 (5 U.S.C. App.), or an authorized reprasentative of e,her of the foragoing
qffiGials shall have access to anc! right to(i) Examine any of the Contractor's or any subcontractors' records that pertain to, arid involve transactions relating to,
this con~ct; and
(ii) Interview any officer or employee regarding such transactions.
(e)
(1) Notwithstanding the requirements ot the clauses in paragraphs (a), (b), and (c), of this clause, the Contractor is not
required to floW down ahy FAR clause in a subcontract for commercial items, other than(i) Paragraph (d) of this clause. This paragraph flows down to all subcontracts, except the authority of the Inspector
General under paragraph (d)(I)~i) does not flow down; and
(ii) Those clauses listed in this paragraph (e)(I). Unless otherwise indicated below, the extent of the flow down shall
be as required by the dause(A) 52.203-13, Contractor Code of Business Ethics and Conduct (Apr 2010) (Pub. L. 110-252, Hie
VI, Chapter 1 (41 U.S.C. 251 note)).
(B) 52.203-15 Whistieblower Protettions Under the American Recovery and ReinVestment Act of
2009 (June 2010) (Section 1553 of Pub. L. 111-5).
(C) 52.219-8, Util~ation of Small Business Concems (Dec 2010) (15 U.S.C. 6371d)(2) and (3), in all
subcontracts that off.er further subcon~cQng opportunities. If the subcon~ct (except subcontracts to small
business concems) exceeds $650,000 ($1.5 million for construction of any public facility), the subcon~ctor
must include 52.219-8 in lower tier subcontracts that offer subcontracting opportunHies.
(D) 52.222-26 Equal Opportunity (Mar 2007) (E.O. 11246).
(E) 52.222-35, Equal Opportun" for Veterans (Sep 201 0) (38 U.S.C. 4212).
(F) 52.222-36, Affirmative Action forWor1<ers.;th Disabilities (Oct 2010) (29 U.S.C. 793).
(G) 52.222-40, Notification of Employee Rights Under the National Labor Relations Act (Dec 201 0)
(E.O. 13496). Flow down required in accordance with paragraph (fj of FAR clause 52.222-40.
(H) 52.222-41, Service Contract Act of 1965 (Nov 2007) (41 U.S.C. 351, et seq,).
(I) 52.222-50, Combating Trafficking in Persons (Feb 2009) (22 U.S.C. 7104(g)).
(J) 52.222-51 Exemption from Application of the Service Contract Act to Contracts for Maintenance,
Calibration, or Repair of Certan Equipment-Requirements (Nov 2007) (41 U.S.C.351 et seq.).
(I<) 52.222-53 Exemption from Application of the Service Contract Act to Contracts for Certain
Service&-Requiremenls (Feb 2009) (41 U.S.C. 351, etseq.).
(L) 52.222-54, Employment Eligibility Verification (Jan 2009).
(M) 52.226-0, Promoting Excess Food Donation to Nonprorrt Organ~tioos. (Mar 2009) (Pub. L.
110-247). Flow down required in accordance .;th paragraph (e) of FAR clause 52.226<5.
(N) 52.247-64, Preference for Privately Owned U.S.-Flag COmmercial Vessels (Feb 2006) (46 U.S.C.
Appx. 1241(b) and 10 U.S.C. 2631). Flow down required in accordance with paragraph (d) of FAR clause
52.247-64.
CONTRACT DOCUMENTS, EXHIBITS, AND AITACHMENTS

Attachment A: Master Service Agr~ment
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PERFORMANCE WORK STATEMENT IPWS)
LOAN LEVEL MORTGAGE DATASET LICENSE SUBSCRIPTION
SEPTEMBER 23, 2011
1.
OVERVIEW I BACKGROUND
On July 21, 2010, Presidem Obama signed lhe Dcxld-Frank Wall Street Refonn and Consumer Protection Act Ithe
"Refonn Act"), which created the Consumer Finandal Protecton Bureau ICFPB). Trtle Xof the Reform Act directs the
US Department ofTreasury Ithe "Treasury Department') to provide interim administretive oversight and transition
oversight a"nd to organize an orderly startup of the Bureau. The Govemment now seeks a Contractor to provide a
subscription to loan level mortgage datasets.
2.
OBJECTIVE
The CFPB requires a Contractor with extensive experience to provide Residential Mortgage Loan-Level Data, which
indudes origination and pertonnante data fields over time. CFPB is looking for the grealest market coverage
possible, both the greatest current lactive loan) coverage and the greatest historical coverage available. The data
must support the highest level of qu~ity, e~denced by use of the data for research purposes, including use in peerreviewed publications. The data must be refreshed with as great a frequency as practicable and the Contractor must
provide if requested, substantial analytical support-ooth on the data itse~ and Ipotentially) for slandard or customized
reports.
3. SCOPE
CF?B seeks to retain access to Loan~evel mortgage datasets to allow the Research, Markets, and Regulations
Division to conducl research to build the e~dentiary record needed for numerous upcoming Congressionally
mandated mortgage rulemakings and reports, and to monitor the mortgage market effectively for emerging trends.
4. REQUIREMENTS
Datasets must meet the following five criteria:
11) Minimum Criteria: Residential Mortgage Loan-Level Data, which inCludes ongination and
pertonn.-nce data fields, over time
(2) Market Data Coverage: We are looking for the greatest market coverage possible,
particularly as it complemenls the LPSlMcDash data.
(3) Historical Data Coverage: We are looking for both the greatest current (active loan)
coverage and the greatest historical coverage available, ideally in one consistent dataset.
(4) Data Quality: The data must support the highest level of quality, e~denced by (among other
things) use of the data for research purposes, induding use in peer-reviewed publications.
(5) Data limelineness: The data must be refreshed with .as great a frequency as.practicable.
(6) Analytical Support: We are looking for a venddr who can provide, upon request, substantial
analytical support-both on the data itse~ and for siandard or customized reports.
Contrectors license subscription must faalrtate CFPB staff in th,jr efforts to'fuffillthe scope of this contrect by
providing loan-level mortgage datasets to all the following:
Monitor mortgage trends
Evaluate policy options
Conduct long-tenn quantnative rese~rch on the impact on detault probability from a wide variety of loan
origination data fields
Amass empirical records for numerous upcoming rulemakings and reports to Congress and the public
CFPB requires "NO" use restrictions. CFPB seeks the contrector to pro~de the following rights:
1. Use
a. Full rights to publish' research, analyses, reports, and other work based on these data-sets
b. No advance notice or advance review of, or permission for publication of CFPB's research results
.hould be nece~ary
c. Right to reference use of the dataset in publications and other public communications using the data
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306
22
d. Right to publish research, analysis, reports, and other work should survive any license (i.e., CFPB
shall still be able to publish work even IT CFPB license to the data has expired)
e. Right to merge the data with all otller datasets without affecting any of our usage or publication nghts
2. Support
a. Include contractual language to codify the support levels datasets will provide with respeel to the
data O.e., SIA, point-of-contaci, time fQ< response, etc.)
b. Contractual language which confirms that, when any new fields are added to the datase\ our data
dictionary is updated and we have a clear explanation of any changes/updates made
c. Optional requirement: access to a web'based portal to access the data sets
3. Enhanced Options
a. Ability to include custom fi~ds in the dataset.
4. Delivery
a. Datasets will be made available in standard formats (e.g. CSV, talHlelimned tex\ XML) thet are
natively compatible for loading into SAS SelVer, PostgreSQl, and MS SQL SelVer environments.
b. Datasets will be made available to CFPB via common file transfer protocols (e.g., SFTP).
c. If authentication is required for acces.ng the product, CFPB will be provided required credentials.
5. REFRESH
If the Contractor, in its product lineJ upgrades or substitutes a new itemwith enhal'lced performance features for an
item that is available under this Contract1 such item or system may be included in this Contract in place of or in
addition to the existing nem or system, provided that an improved ratio of performance versus pnce is attained. The
Contractor shall notify the Contracting Offcer of any such changes in ,s product line that affect this Contract promptly
upon commercial announcement or availability of the-change. Price fair and reasonableness will be determined prior
to the issuance of a del~ery order for any new proposed 'erns.
6. QUALITY ASSURANCE SURVEILlANCE PIAN (QASP)

The Conlracting Officets Technical Representative (COTR) will summanze and document the Contractots
performance in the categories listed below (evaluation based on meeting the requirements of this PWS):
Quality of SelVice
Cost Cootrol
TImeliness of Performance
Business Relations
SUlVeiliance method. Random Evaluation. This metllod employs a ' spot check' style of evaluation and may be
adjusted, based on qualtty trends. The Government retains the nght to inspect all requirements of the contract.
Unacceptable performance will be recorded and the Contractor shall be required to correct the unacceptable condition
wtthin a 24-hour time penod. If the Contractor does not correct the unacceptable condition within 24-hours, the COTR
will notify the Contracting Officer who will take appropnate administrative action for unacceptable performance. iMlen
an observation indicates defective performance, the CaTR will require the Contractor to initial the observation. The
initialing of the obseMtion does not constitute concurrence with the obselVation; n on~ indicates acknowledgement
that the Contractor has been made aware of a potentially defective performance.
7.0 TASK ORDER REQUIREMENTS
Any TO issued dunng the effective penod of this contract and not completed w,hin that penod shall be
completed by the Contractor within the time specified in the TO. The contract shall govern the Contractors
and Goveminenfs nghts and obligations with respeel to that TO to the same exient as IT the TO were
completed dunng the contracfs effective penod; provided, that the Contractor .shall not be required to make
any deliveries under this contract after 5 years from expiration of the contract.
TASK ORDER REQUESTS
a.
Task Order Requests. The Government shall issue each TO Request electronically to the Contractor
for review and preparation of a proposal. Each TO Request shall specify the technical req~irements , the
desired deliverable produC\ performance standards, documentation standards, QASP, acceptance erRena,
dient agency benchmarks, and performance schedule, in suffioent detail to permn an accurate pnce, work
hours, other resources and completion date by the Contractor. It is the Contractots responsi ~ltty to propose
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307
23
approprtate labor categortes, within the scope of the contract, and level-of-effort necessary to pertorm the
services or provide the d.eliverables described in each TO Request.
b.
The following types ofTask Orders may be issued:
Fixed-Price: This is a task for which there are reasonably definite reqUirements, and for which there is one or
more tangible deliverables.
Labor-Hours: This is a task thai addresses a requirement where ther,e are no ODCs and it is not possible to
define the work specffically e.hough to permIT the development of a firm fixed-prtce estimate. No matertals are
necessary in the pertormance of the work. Labor-hour TOs shall be issued with a not-to-exceed ceiling prtce.
7. PERIOD OF PERFORMANCE
The pertod of pertorm,nce for this contract will be for a 12 month base pertod and four 12 month option pertods.
8. PLACE OF PERFORMANCE
The contractor shall perform services at the following locations:
Con,s!Jmer Financial Protection Bureau
Fifth Floor
1801lSt.NW
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308
ADDENDUM TO 52.212-4, CONTRACTTERMS AND CONDITIONS - COMMERCIAL ITEMS (JUN 2010)

INVOICES
Invoices shall be submitted electronically to the &-mail address sh""" in Block 18a, page 1. Protected
Microsoft Excel files are the preferred fonmat; however, Adobe Acrobat Portable Document Fonmat (PDF) and
Microsoft Word are also acceptable. For payment and invoice questions contact Actounting Services Division
at (304) 481J.l!300.
PAYMENT INFORMATION:
Receive a free email nouce of your electronic payment Register at 1.WNI.ipp.gov.
OVERPAYMENTS
In accordance \\1th 52.212-4 section (i) 5 OVerpayments: Accounts Receivable Conversion of Check Payments
to EFT: If the Contractor sends tile Government a check to remedy duplicate contract finandng or an
overpayment by the govemmenl, it \\111 be converted into an electronic funds transfer (EFT). This means the
Government will copy the check and use the account information on ~ to electronically debit the Cootractor's
account for the amount of the cheel<. The debtt from the Contractors account \\111 usually occur \\1thin 24 hours
and \\111 be shown on the regular account statement.
The Contractor \\111 not receive the onginal check back. The Govemment \\111 destroy the Contractors anginal
chack, but \\111 keep a copy of it. wthe EFT cannot be processed for technical reasons, the Contractor
authonzes the Govemment to process the copy in place of the anginal check.
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Please ensure that the order number (Block 4) is clearly visible on all shipping/service documents, containers,
and invoices.
309
Clarity Services Inc.

PARKERSBURG, lIN 26106-1328

September 26, 2012
Sarita Fratarolli
Installment and Liquidity Lending Markets
Research, Markets & Regulations
1700G.StNW
Washington DC 200052
Dear /1.0\5. Fraltaroli:
In accordance with the procurement policies and procedures contained in the Treasury Directives
~"anual, you are hereby designated as Contracting Representative (COR) in connection with the techniCJ[
phases of contract number TPD-CFP-12-C-OO 11, awarded 10 Clarity Services, Inc for the PayDay
Lending Datasets.
The COR represents the requesting organization throughout the 3Ci1uisition cycle. In genera~ your
responsibilities include coordinating all required program office actions, placing task orders and
pro\~ding assistance during administration of the contract. The Contracting Officer (CO) and the
contract administrator are your points of contact in the Procurement office.
DESIGNA nON OF COR
A~ COR, your name appears in the contract schedule. A copy of this letter will also be provided to the
Contractor. This letter sets forth in detail the full extent of your authority and limitations. It does not
change or supersede the established line of authority and/or responsibility of any organization. This
appointment as COR applies to the abo"e-referenced contract only, and shall tenninate on completion of
tlte contract.
SCOPE OF SPECIFIC RESPONSIBILITIES

Administration:
Represent and coordinate with the requesting organization, program office(s) involved, and management,
all tedlIlical activities relating to this contract;
Identify and monitor key administrative actions and accomplishment dates;
r.,lonitor the Contractor's performance in meeting the technical requirements of the contract to assure that
performance is strictly within the scope of the contract;
Detennine the level of quality assurance evaluation required to insure that services are received in
accordance with the contract;
Write and execute a surveillance plan, as appropriate;
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Represent the Government in certain conferences with the contractor and prepare memoranda for the
record of pertinent facts;
310
Confirm all significant technical instructions to the Contractor and provide a copy of the confirmation to
the CO;
Maintain a filing system and a contract working file containing a complete history of actions taken with
regard to the contract;
Refer to the CO those matters, other than purely technic.11 issue problems, which may significantly affect
the contract;
Furnish thc CO a copy of conference reports and C(lrrespondence;
Coordinate with the CO on the content of any contractually significant correspondence addressed to the
Contractor in order to ensure technical and historical accuracy and to prevent possible misunderstanding
or the creation of a condition that may be made the basis of a later claim. All correspondence addressed
to the Contractor will be signed by the CO;
Report to the CO and Legal Counsel suspected procurement frauds, bribery, conflicts of interest, and
other improper conduct;
Assure that the Contractor has a current facility clearance as well as appropriate clearance for his
personnel to have access to buildings, materials, equipment, etc.;
When required, furnish the CO a formal request for termination; and,
Inspection and ACCfptance;
Inspect allllork for full compliance with contract requirements;
Promptlyreject all work that does not comply with contract requirements and immediately notify the CO;
Am~se the
CO uthe Contractor fails \0 remove, correct, or replace rejected work promptly;
Provide technical guidance (not direction) am~sing the Contractor of formal appeal rights when there is a
disagreement;
Prepare and maintain a running list of items that remain at variance with contract requirements, apprising
both the Contractor and the COof corrective action or the need for it;
Maintain a master copy of the official list of defects and omissions; and,
Ensure that all defects and omissions are corrected or completed.
Administer contract changes pw.'iously authorized by CO; and,
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Ensure that the Contractor provides formal proposals for contemplated changes.
2
311
Financial Ma na ~ m t'nt Issues:

Review the Contractor's invoices to insure that they reflect accurately the work completed in accordance
with the requirements of the contract and certify acceptance,
Monitor financial management controls by reviewing overall expenditures against obligations to insure
that sufficient, but not excess, funds are available for use under the contract; and,
Advise the CO of any delay factOlS (strikes, weather, etc.) and record their impact; and,
lnfonn the CO when a Contractor is known to be behind schedule, with the reasons therefore, and
coordinate with the CO corrective action necessary to restore the contract schedule.
Submissions:
Dctennine (from the contract) and track the number and types of submittals required from the oontractor,
~laintain
a record of submittals on a current basis;
Approve or reject submittals as provided in the contract documents; and,

Furnish the CO a notice of satisfactory or unsatisfactory completion
EXCLUSIONS FROM COR R&WONSIBILITIES

Requirements of law, regulation, or Treasury procedure prohibit the delegation of or responsibility for
certain actions related to contracts. For this reason, you are advised that you may not:
Make commitrncnis or promises to Contractors relating to award of contracts;
Write contract requirements around the product or capacity of one souret',
Solicit proposals;
Award, agree to, or execute a contract or contract modification;
Issue instructions to Contractors to start or stop work;
Obligate, in any W3Y, the p3)ment of money by the Government;
Approve items of cost not specifically authorized by the contract;
Direct changes;
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312
Execute supplemental agreements;

l\1ake a final decision on any matter that would be subject to appeal under the Disputes clause of the
contract;
Cause the contractor to incur costs not specifically covered by the contract with the expectation that such
costs will be reimbursed by the Goverrunent;
Tenninate for any cause the Contractor's right to proceed;
Authorize delivery or disposition ofGoverrunent-furnished property not specifically authorized by the
contract;
Give guidance to ContractOlS, either orally or in writing, which might be interpreted as a change in the
scope or terms of the contract;
Discuss procurement plans or any other advance infonnation that might provide preferential treatment to
onc finn o\-er another when a solicitation is issued for a competiti\-e procurcmrnt;
Approve Contractor's requests for public release of infonnation regarding work being performed under
the contract; or,
Redesignate any of your assigned duties unless specifically authorized by the CO to do so.
RE-DESIGNATIONOF RESPONSIBILITIES:
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The above designated responsibilities maynot be re-designated, except for clerical tasks associated with
that authority, Changes in the designation of COR will be made through the Contracting Officer and
letter appointment as the need arises. If it becomes necessary to make a change in the CORdesignation,
lOU must notify the CO and provide the name of your replacement. You must provide any active files to
the named replacement and send any inacti\"e files to BPD or to other designated storage area as directed
by CO.
313
I am providing you with one copy of this letter of designation. Please sign in the space provided below to
indicate rou ha\'e read and will comply with the responsibilities outlined in the letter, make a oopy of this
letter for your files, and return the original (scanned or faxed copy of this page is acceptable) to Money
Gardner al:
Any questions regarding the responsibilities outlined in
this letter should be referred to the contract administrator or the CO at
contractadministration1j:bpd,tre3s.gov.
Sincae1y,
Jacob Oberlin
Contracting Officer
ACCEPTED: ~_~=~~_~~____
Contracting Officer's RepresmMive
DATE:
Contract Number:
1PJ).Cfp12~.(}()17
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314

PARKERSBURG, lIN 26106-1328
September 26, 2012
Yuh Wen LING

Installment and Liquidity Lending r..laikets
Research, ~larkets & Regulations
\700G,StNW
Washington OC 200052
Dear r..is. Ling:

In acoord:mce with the procuranenl policies and procedures contained in the Treasury Directives
Manual, you are hereby designated as Contracting Representative (COR) in connection with the technical
phases of contract number TPD-CFP12.c~ 11, awarded to Clarity Services, Inc for the PayDay
Lending Da\asets.
The COR represents the requesting organization throughout the acquisition cycle. In genera ~ your
responsibilities include coordinating all required program office actions, placing task orden and
pro\~ding assistance during administration of the contract The Contracting Officer (CO) and the
contract administrator are your points of conUc\ in the Procurement office.
DESIGNATIONOF COR
As COR, your name appears in the contract schedule. Acopy of this letter will also be prol'ided to the
Contractor. This lettt'f sets forth in detail the full extent of your authority and limitations. It does not
change or supersede the established line of authority and/or responsibility of any organization. This
appointment as COR applies to the above-feft'fenced contract only, and shall tenninate on completion of
the contract.
SCOPE OF SPECIFIC RESPONSIBILITIES

Administration:
Represent and coordinate with the requesting organization, program office(s) imolved, and management,
all technical activities relating to this contract;
Identify and monitor key administrative actions and accomplishment dates;
Monitor the Contractor's performance in meeting the technical requirements of the contract to assure that
perfonnance is strictly within the scope of the contract;
Detennine the 1e\eJ of quality assurance e\'aluation required to insure that services are received in
accordance with the contract;
VerDate Nov 24 2008
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Write and executc a SIIf\'cillance plan, as appropriate;
315
Represent the Government in certain conferences with the contractor and prepare memoranda for the
J'C\:ord of pertinent facts;
Confinn all significant technical instructions to the Contractor and provide a copy of the confumation to
the CO;
~laintain a filing system and a contract working file CQIltaining a complete history of actions taken with
regard to the contract;
Refer to the CO those matters, other than purely techniCJI issue problems, which may significantly affect
the CQIltract;
Furnish the CO a copy of conference reports and correspondence;
Coordinate with the CO on the content of any contractually significant correspondence addressed to the
Contractor in order to ensure technical and historical accuracy and to prevent possible misunderstanding
or the creation of a condition that may be made the basis of a later claim. All correspondence addressed
to the Contractor will be signed by the CO,
Report to the CO and Legal Counsel suspected procurement frauds, bribery, conflicts of interest, and
other improper conduct;
Assure that the Contractor has a current facility clearance as well as appropriate clearance for his
personnel to ha\e access to buildings, materials, equipment, etc.;
When required, furnish the CO a fonnal request for tamination; and,
Ins!K'ction and AcceplanCl':
Inspect aU work for full compliance with contract requirements;

Promptlyreject all work that does not comply with contract requirements and immediately notify the CO;
Am~se the
CO if the Contractor fails to remove, correct, or replace rejected work promptly;
PfO\~de technical guidance (not direction) am~sing the Contractor offonna[ appeal rights when there is a
disagreement;
Prepare and maintain a running list of items that remain at variance with contract requirements, apprising
both the Contractor and the CO of corrective action or the need for it;
r-.laintain a master copy of the official list of defects and omissions; and,
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Ensure that all defects and omissions are corrected or completed.
316
Administer contract changes pM'iousiy authorized by CO; and.

Ensure that the Contractor provides formal proposals for contemplated changes.
Financial ManaITment Issul'S:
Review the Contractor's invoices to insure that they reflect accurately the work completed in accordance
with the requirements of the contract and certify acceptance.
r..lonitor financial matt.:lgement controls by reviewing Ol'erall expenditures against obligations to insure
that sufficient, but not excess, funds are available for use under the contract; and,
Am~se the
CO of any delay factors (strikes, weather, etc.) and record their impact; and,
Inform the CO when a Contractor is known to be behind schedule, with the reasons therefore, and
coordinate with the CO corrective action necessary to re;tore the contract schedule.
Submissions:
Determine (from the contract) and track the number and types of submittals required from the contractor,
Maintain a record of submittals on a current basis;
Approve or reject submittals as provided in the contract documents; and,
Furnish the CO a notice of satisfactory or unsatisfactory completion
EXCLUSIONS FRO\I COR RESPONSIBILITIES

RC1]uiremenls of law, regulation, or Treasury procedure prohibit the delegation of or re;ponsibility for
certain actions related to contracts. For this reason, you are adl'ised that you may not:
Make commitments or promises to Contractor> relating to award of contracts;
Write contract requirements around the product or capacity of one source,
Solicit proposals;
Award, agree to, or execute a contract or contract modification;
Issue instructions to Contractors to start or stop 1I'0rk;
Obligate, in any way, the pa}mcnt of money by the Government;
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Approve items of cost not specifically authorized by the contract;

3
317
Direct changes;
Execute supplemental agreements;
Make a final decision on any matter that would be subject to appeal under the Disputes clause of the
contract;
Cause the contractor to incur costs not specifically covered by the contract with the expectation that such
costs lI'ill be reimbursed by the Govcnunent;
Tenninate for any cause the Contractor's right to proceed:
Authorize delivery or disposition ofGorcnunent-fumished property not specifically authorized by the
contract;
Gi\'e guidance to Contractors, either orally or in writing, which might be interpreted as a change in the
scope or terms of the contract;
Discuss procurement plans or any other advance infonnation that might pro\~de preferential treatment to
one finn O\'er another when a solicitation is issued for a competiti\'e procurement;
Approve Contractor's requests for public release of infonnation regarding work being performed under
the contract; or,
Redesignate any of your assigned duties unless specifically authorized by the CO to do so.
RE,DKr.;IGNAT10NOF RESPON'SIB11,lTlES:
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The above designated responsibilities rna}' not be re--designated, t.xcept for clerical tasks associated with
that authority, Changes in the designation of COR will be made through the Contracting Officer and
letter appointment as the need arises. If it becomes necessary to make a change in the COR designation,
you must notify the CO and provide the name of your replacement. You must provide any active files to
the named replacement and send any inacti\'e files to BPD or to other designated storage area as directed
by CO.
318
I am providing you with one copy of this letter of designation. Please sign in the space provided below to
indicate rou ha\e read and will comply with the responsibilities outlined in the letter, make a oopy of this
letter for your files, and return the original (scanned or faxed copy of this page is acceptable) to Money
Gardner al:
. Any questions regarding the responsibilities outlined in
this letter should be referred to the contract administrator or the CO at
contractadministration1j:bpcl.tre3s.gov.
Sincerely,
Jacob Oberlin
Contracting Officer
ACCEPTED: ~_~=~~_~~____
Contracting Officer's RepresmMive
DATE:
Contract Number:
1PJ).Cfp12~..(}()17
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319
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__ ,,'''','''l4ICf011'1.JII
I'IIEY!OUIIUIll)IOl5liOr _ 1
320
2 of
"
-~
" "
Y:HEru..Ea9.MJEs.sER\'ICES
"
18
"
~~
.~
Gov ' t COR :

Sarita Frattaroli
Tel :
202- 435 - 1465
E- J:lail :
Sarita . Frattaroli@cfpb .gov
A.ltemate Gov ' t COR :

Yuh Wen LING
Tel :
202- 435 - 9451
E- mail :
YuhWen . Ling@cfpb. gov
Accounting Info :
CFP55 /7SFXXXX - 2012- 61 0001 - CFP4050000 - 2512 - 0000000
- XXX- XX - XXXXXXXXX- XXXXXXXXX - XXXXXXXXX
Period of Perfonnance : 09/ 26/2012 to 02/25/2014
0001
PayDay Lending Da t aSet.s in accordance with the
312 , 660 . 00
PWS .
Ana lysis and Reports - $308 , 488 . 00
Travel - $4 , 180.00
, PLEASE NOTE : If
does not
participatoo in thoo da t a .study, a cost of $100, 000

will be eliminated from the Firm Fixed Price .
Obligatood Amount : $312, 660.00
Amount : $291,000.00
Amount : $21 , 660.00

Period of Perfonnance: 09/27/2012 to 02/26/2013
Continued
31. QlWiTlH Il COlIMN 11 HASeEEN
o RECEIVED
ACCEPTED, .... DCOOl'ORNS TO TtE CONTR.O.CT, EX.CEPT AS
o IISI'ECTfO
o NOIED
OF .'.IJIHORIlI:OGOVBlNMENT R~ESENTAT"'E
131<""T<
Qb
SIGN~TURl'
.)2.
IoIAl. IKi I\CtIPESS OF AAHORIliO GOVERN"'NT REPRESENTATIVE
31< PIlNTEO NAME .... OT~tE OF .o.ulHORilEO GOVERNMENT
Rl'PIlESENT~TrvE
311 TELEPHONE lIJo,ftR ~ .otITHORilED GOVERNr.t:NT Rl'PIlESENTATI'IE
31') E.w.l Of .'.IJIHOR[ED GOVBlmlEm R~ESENTAT"'E
!3 SHP ",-""eER
VOUCIERN .... OCR
AAlOUNTVERfED
31 CHECK MJr.Il~
PAYloENi
FRRtCTfOR
OCOM .... ETE
OPAAllAl
)8
OPARTIOI.
OFII.<I.
SoIlACCOlI<TNlI"BER
138 SIlI':iUCHER NUhl EiER
0'-
too PAOBY
'" ICEilTHTIRSACOXO<T ISCORRECT AJI;lPllOl'ER FORPAVMfNT

ll. SIGNAJURI' .... omlEOFCERTIFYNG~fnR
'1. RECEM'D6Y
(PMIJ
'10""TE
'1b RECENE1)AT (\.oc8""'J
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18
_OFOFFEI!Of!OROlMTPAC~
ClARlTY SERVICES INC
-~
0002
Ic)
181
IAI
- _.0
ID
lEi
CI.t'I
IF)
~tion P~riod
1 - PayDay Lending Data5ets refresh

in accordance with the PWS .
Phase Note ;
if C,PB choses t o participatIO in a
econdary optional dau pull (6/12 month."
does not take part in that
Mly.si~ , M additional $25,000 will be
liminated from the Firm Fixed Price .
Amount : $65 , 300 . 00(Option WM Item )
Pericxl of Performance: 02/27/2013 to 08/26/2013
'0'
0003
~tion
Period 2 - PayDay Lending Data5ets R..fresh

in accordance with the rws .
Pl"Me Note :
if CFPB choses t o participat .. in a
econdary optional data pull (6/12 months)
does not take part in that
Mlysis, an additional $25,000 will be
liminated from the Firm Fixed Price .
'0'
Amount : $65 , 300.00(Opt ion !.ine Item)

Invoicing : upon compl~tion of ba.s~ period of

perfomance and each cpt ion peri od of perfomance .
ft~r award , any qu~.s tion.s or i.s.su~.s related to
this procurement will be handled by the Contract
Mministration Branch at
ContractAdministration@bpd . treas . gov . When
~nd.ing an ~~mail to this address , please include
th~ award nU!Dh~r in th~ .subj~ct lin~ of th~
- mail .
SI<1$<()4, ,1281
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4
52.2124
CONTRACT TERMS AND CONDITIONS - COMMERCIAL ITEMS (FEB 2012)
(e) Inspection/Acceptance, The Contractor shall only lender for acceptance those ~ems that confo rm to the
requirements of this contract The Government reserves Ihe right to inspect or test any supplies or services
that have been tendered for acce~ance. The Government may require repair or replacement of
nonconforming supplies or reperformance of nonronforming services al no increase in cootracl price If
repa ir/replacement or reperformance 'Nil l not correct the defects or is not possible, th e Government may
seek an equitable I=fice reducbo n or adequate co nsideration for acceptance of oonco nlorming supplies or
services. The Government must exercise its post-acceptance rights(t ) Within a reasonable time after the defect was discovered ar should have been discovered; and
(2) Before an y substantial change occurs in the condition of the item, unless the change s due to the
defect in the ~em

(b) Assignment. The Contractor or its assignee may assign its rights to receive payment due as a resuK of
performance of this contract to a bank, trust company, or other fi nancing institution, including any Federal lending
agency in ac{;Ordance with the Assignmentof Claims Act (31 USC. 3n7). However, when a third party makes
payment (e.g., use of the Governmentwide commercial purchase card), the Contractor may not assign its rights to
re<:eive payment under this contract.
(c) Changes. Changes in the terms and cond~ions of this contract may be made only by IY!itlen agreement of
the parties.
(d) Disputes. This contract is subje<:t to the Contract Disputes Act of 1978, as amended (41 US.C 601--613)
Failure of the parties to this contract to reach agreement on any request for e~itable adjustment claim, appeal or
action arising underor relating to this contract shall be a dispute to be resolved in accordance with the clause at FAR
52.2331, Disputes, which is incorp:lIaled herein by reference. The Contractor shall proceed diligently.,.,;th
performance of this contract, pending fina l resoluton of any dispute arisin g under the contract
(e) Definitions, The clause at FAR 52,2021 , Defin~ion s, s incorporated herein by reference.
(n Excusable delays. The Contractorshall be liable for defauH unless nonperformance is caused by an
occurrence beyond the reasonable control of the Contractor and .,.,;thout its fauH or negligence such as, acts of God or
qtJarantine restrictions, strikes, unusually severe weather, and delays of common carriers. The Contractor shall notify
the Contracting Officer i1 writing as soon as ~ is reasonably possible after the commencement of any excusable
delay, setting lorth the full particulars in connection tIlerewitll, shall remedy such occurrence with all rea sonable
dispatch, and shall prornlily give written notice to tile Contracting Officer of tile cessation of such occurrence
(g) Invoice. The Contractor shall submij an orginal invoice and three copies (or ele<:tronic invoice, if authorized,)
to the address designated in tile contract to receive invoices An invoice must include-(i) Name and address of the Contractor,
(ii) Invoice date and number,
(iii) Contract number, contract line ijem number and, if applicable, the order number,
(iv) Desctiliion, ~antity, u n ~ of measure, un~ price and extended !=rice of the rtems delivered;
(v) Shipping number and date of shipment, including the bill of lading number and weight of shipment if shipped
(vi) Terms of any discount for ftOm~ payment offered;
(vii) Name and address of official to whom payment is to be sent
(viii) Name,@e,andphonenumberofpersontobenotified ineventof defective invoice; and
(ix) Taxpayer IdentifICation Number (TIN). TMe Contractor shall include its TIN only ~ required elsewhere in this
contract
(x) Ele<:tronic funds transfer (EFT) banking information
(A) The Contractor shall include EFT banking info rmation only if required elsewhere in tIlis contract
(8) If EFT banking information is not required to be on the invoice, in orderforthe invoice to be a proper
invoice, the Contractor shall Mave submitted correct EFT banking information in accordance witll tMe applicable
solicitation ftOvision, contract ctallSe (e.g., 52.232-33, Payment by Ele<:tronic Funds Tra nsfer---Central Contractor
Registration, or 52, 23234, Payment by Electronic Funds Transfer-Other tMan Central Contractor Registra~on), or
applicable agency procedures
(C) EFT banking informationis not required if the Govemment waived \t1e requirement to pay by EFT.
(2) Invoices will be tlandled in accordance with the Prompt Payment Act (31 U,S,C. 3903) and OffICe of
Management and Budget (OMB) promli payment regulations at5 CFR 1315
(h) Patent indemnity. The Contractorshall indemnify the Govemment and its officers, employees and agents
against iabilrty, including costs, for actual or alleged dire<:t or cootributory infri ngement 01, or inoocement to infrilge,
any United States or foreign patent, trademarJr: or copyrigh~ arising out of the performance of this contrac~ provided
the Contractor is reasonably noUfied of such claims afld proceedings
(i) Payment. (1) Items accepted. Payment shall be made for items accepted bot the Government ttlat have been
delivered to the delivery destinations setlorth in tIlis contract
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5
(2) Prompt payment The Government wi ll make payment in accordance wiIIllhe Prompt Payment Act (31
U,S,C. 3903) and OffICe of Management and Budget (OMB) prompt pay regulations at 5 CFR 1315.
(3) Ele<:/rolljc Fuoos Transfer (EFT). If the Government makes payment by EFT, see 52.212-5(b) for the
appropriate EFT clause.
(4) Discount. In conn ection with any discount offered for early payment, time shall be computed from the date of
the invoice. For the purpose of computing the discount earned, payment shall be considered to have been made on
the date lIIhich appears on the payment check or the specified payment date ~ an electronic fu nds transfer payment is
made
(5) Overpayments. lIthe Contractor becomes aware 01 a duplicate contraclfinancing or invoice payment or that
the Government has otherwise overpaid on a contract financi ng or invoice payment, the Contractor shall(i) Rem~ the overpayment am::lunt to the payment office cited in the contract along with a description of the
overpayment including the--(A) Circumstances of the overpayment (e,g., duplicate payment erroneous payment Iquidation errors,
date(s) of overpayment);
(8) Affected contract number and delrvery order number, ~ applicable;
(C) Affected contract line rtem 01' subline ~em, ~ applicable; and
(D) Contractor lXIint of contact
(ii) Provide a copy oftne remittance and supporting documentation to the Contracting Officer
(6) Interest.
(i) All amounts that become payable by the ContractQrto the Government under this contract shall bear
sirnple interestlrorn the date due until paid unless paid within 30 days of becoming due. The interest rate shall be the
interest rate established by the Secretary of the Treasury as provided in Sectioo 611 01 the Contract Disputes Aclol
1978 (Public law 9~563), l'Ihich is applicable to the period in ...mich the amount becomes due, as pfO\>ided in (i)(6)(v)
of this clause, and then at the rate applicable for each sixmonth period as fixed by the Secretary until the amount is
paid
(ii) The Government may issue a demand for payment to the Contractor upon find ing a debt is due under the
contract
(iii) FJnaldeci3ions. The Contracting Officerwill issue a final decision as req uired by 33.211 if(A) The Contracting Officer and tile Contractor are unable to reach agreement on the existence or amount
01 a debilYith in 30 days;
(8) The Contractorfails to li~idate a dett pre'o'iously demanded by tile Contracting Officerwithin the
bmeline specified in the demand lor payment unless the amounts were not repa id because the Contractor has
req uested an installment payment agreement or
(C) The Contractor requests a deferment 01 coDection on a debt previo usly demanded by the Contracting
Officer (see RQU).
(iv) If a demand for payment was previously issued for the dett, the demand for payment included in the fina l
decision shall identify the same due date as the original demand 101' payment
(v) Amounts shall be due at the earliest of the 10110lYing dates:
(A) The date fixed under this contract
(8) The date olthe first wrjten demand lor payment including any demand for payment resullinglrom a
defauH termination
(vi) The interest charge shall be comp.Jted for the actual number of calendar days involved beginning on tile
due date and ending on-(A) The date on which the designated office receives paymentlrom the Contractor;
(8) The date 01issuan ce 01 a Government check to tile Cootractor from l'Ihich an amount otherwise
payable has been withheld as a cred ~ against tile contract det:t; or
(C) The date on l'Ihich an amount withheld and applied to the cootract debt would otheMise have become
(vii) The interest charge made under this clause may be reduced under the procedures prescribed in ~
.? of the Federal Acq uisition Regulatioo in effect on the date of this contract
Ul Risko! loss. Unless tile contract specificany provides otllerwise, risk 01 loss or damage to the suppties
provided under th is contract shall rema in with the Contractor until. and shall pass to the Government upon:
(1) Delivery of the supplies to a carrier, if transportation is f.o.b origin; or
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(2) Delivery 01 the supplies to the Govemment at the destination specified in the contrac~ ~ transportation is
I.o,b, destination.
(k) Taxes, The contract price inctudes al appicabte Federat, State, and local taxes and dutes.
(I) Termination fer" the Govl'nment's convenience. TMe Government reserves the right to terminate th is contract,
or any part hereol, for its sole convenience. tn the event 01 such termination, the Contractor shall immediatety stOjJ all
wo r\( hereunder and shalt immedialety cause any and alt of its suppliers and suocontractors to cease work, Su~ect to
the terms of this contract, the Contractor shall be paid a pertentage 01 the contract pfice reflecting the percentage of
the work performed prior to the notice 01 te rminanon, plus reasonable charges the Contractor can demonstrate to the
satisfaction of the Govemment using its standard record keepng system, have resuHed from the termination, The
Contractor shalt not be required to comply with the cost accounting standards or contract cost principles for this
purpose. This paragraph does not give the Government any right to aud~the Contracto~s records. The Cootractor
shalt not be paid for any work performed or costs incurred which reasonably could have been avoided
(m) TI'minalion ffXcause. The Governmenl may terminate this contract, or any part hereof, for cause in tile
event of any defauH by the Contractor, I)( if the Contractorlais to comply with any contract te rms and conditions, or
lails to provide the Government upon request with adequate assurances olfuture performance, In the event of
termination lor cause, the Government shall not be liable to the Contractorlor any amount for supplies or services not
accepted, and the Contractl)( shall be liable to the Government for any and alt rights and remedies provided by law, II
~ is determined thatlhe Government improperty terminated th is contract lor delauK, sucll termination shall be deemed
a termination fo r convenience.
(n) Title, Unless specified e5"o1oflere in this contract title to items fumished under this contract shalt pass to the
Government upon acceptance, regardless ofwhen or where the Government takes physical possession.
(0) Warranty. The Contractorwarrants and implies that the items delrvered hereunder are merchantable and frt
lor use forthe particular purpose described in this co ntract
(p) Limitation of liability. Except as otherwise pro't'ided by an express warranty, the Contractorwilt not be liable
to the Government fo r conseq uential damages resuHiflll lrom any defect or deficiencies in accepted items.
(q) Other compliances, The Contractor shall colTJjllywith alt applicable Federal, State and local laws, executive
orders, rules and regulations applicable to its performance under this contract
(r) Comp/iance with laws unique 10 Govemmenlcon!racls. The Contractor agrees to comply with 3t U.SC, 1352
relating to limitations on the use of appropriated funds to inftuence certain Federal contracts; 18 U.S.C 431 relating to
officials not to benefit; 40 U.SC 370t et seq" Contract Work Hours and Salety Standards Act; 41 USC 5t-58 AntKickbackAct of 1986; 41 U.S.C 265 and 10 USC. 2409 relating to whistle blower protections; 49 U.S.C. 401 18 Fly
American; and 41 U.SC. 423 relating to procurement integrity
(s) CXderof precedence Any inconsistencies in this solicMon or contract sha. be resolved by giving
precedence in the 101l0l'.1ng order
(1) The schedule of suppliesfser.ices
(2) The Assignments, Disputes, Payments, Invoice, Other Compliances, and Compliance with laws
Unique to Govemment Contracts paragraphs of th is clause
(3) The cJause at 52,212-5
(4) Addenda to this solicitation I)( contract including any license agreements fl)( computer software
(5) Solicitation provisions if this is a solicitation.
(6) Other paragrap'ls oIthis clause
(7) The Standard Foon 1449
(8) Other documents, exhibits, and attachments
(9) The specrticalion
(t) Central Contractor Registration (CCR)
(1) Unless exempted b an addendum to this contract, the Contractor is responsible during performance and
through final payment 01 any contract lor the accuracy and colTJjlleteness of the data within the CCR database, and for
any liability resutting from lIle Government's reliance on inaccurate or incomplete data. To remain registered in the
CCR database after the i n~ial reg istration, Ihe Contractor is requ ired to review and up:jate on an annual basis from
the date of initial reg istration or su~equent updates its informanon in the CCR database to ensure ~ is current
accurate and complete Updating information in the CCR does notalter the terms and conditions of this contract and
is not a substitute lor a propeny executed contractual document.
(2)(i) II a Contractor has legally changed its bllSiness name, "doing oosiness as" name, or division name
(....t1ichever is shown on the contract), or has transferred the assets used in performing lt1e contract, but has not
completed the necessary req uirements regarding novation and change-<ll-name agreements in FAR Subpart 42, 12,
the Contractor shall provide the responsible Contracting Officer a minimum of one business day's written notincation
of its intention to (A) change the name in the CCR database; (6) comply with the requirements 01 Subpart 42.12; and
(C) agree in writi ng to the timeline and procedures specified by the responsible Contractiflll Officer. The Contractor
must provide with the notification sufficient documentation to support lt1e legally changed name.
(ii) Iflhe Contractorla ils to comply with the req uirements of paragraph (t)(2)(i) 01this cla use, orfails to
perform the agreement at paragraph (tX2)@C)ofthisciause, and, in the absence 01 a properly executed novation or
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change-<lf-name agreemen~ the CCR information that shows the Contractor to be otherthan the Contractor indicated
in the contract will be considered to be iocooect infoonation within the meaning of the 'Suspension of Paymenr
paragraph of the electronic fu nds transfer (EFT) clause of this contract.
(3) The Contractor shall not change the name or address for EFT payments or manual payments, as
appropriate, in the CCR record to reflect an assignee for the PUlJXlse of assignment of claims (see Subpart 32.8,
Assignment of aaims). Assig nees shall be sellirately registered in the CCR c!ataoose. Information provided to the
Contractor's CCR record that indicates payments, including those macle by EFT, to an ultimate recipient other than
that Contractor wi ll be considered 10 be incorrect information within the meaning of the 'Suspension of paymenr
paragraph of the EFT dause of this contract
(4) OHerors and Contractors may ottain information on registration and annual confirmation requ irements via
CCR accessed through hltps.lAflflV.atquisifioo.govor by calting 1-8882272423 or 26g9615757.
ADDENDUM TO 52.212-4, CONTRACT TERMS AND CONDITIONS - COMMERCIAL ITEMS (FEB 2012)
ELECTRONIC INVOICING AND PAYMENT REQUIREMENTS

Intemet Payment Platform OPP) is a secure web-based electronic invoicing and payment information service available
to all Federal agencies and their supplier t1{ the U.S. Treasury's Financial Management Service. IPP allows Fecleral
agencies and their suppliers to exchange electronic purchase orders, blanket POs, invoices, and payment information
in one easy to access web portal. This service is free of charge to government agencies and their suppliers,
induding services and support
The preferred method for invoicing is through IPP. The IPP wet:6~e address is httos:lfwMy.ioo.gov. Contractor
assistance with enrollment can be obtained by contacting the Bureau of the Public Debt's IPP Team at 304-480-8000,
Option 7 or IPP Production Help desk via email ippgrouC@OOs.frb.oraorphone(866)9733131.
II the Contractor is unable to utilize IPP for submitting payment requests, invoices may be submitted electronically to
the email address shown in Block 18a, page 1 after completing the IPP Waiver Form and submitting Hvia emailto
contracta dministration@OOd.lreas.gov (see IPP Waiver Attachment). Adobe Acrobat Portable Document Format
(PDF) and Microsoft Word are accelXable formats. Invoices shall contain th e information required in FAR 52.212
4(9).
PAYMENT AND INVOICE QUESTIONS
For payment and invoice questions, go to httt::lJw.wJ.ippgov or contact the Accounting Services Division at (304)
480-8000 option 7 orvia email at AccountsPayable@bpd.lreas.gov
OVERPAYMENTS
In accordance with 52.2124 section (i) 5 CNerpayments Accounts Receivable Conversion 01 Check Payments to
EFT: If the Conlractorsends the Govemment a check to remedy duplicate contractlinancing or an overpayment by
the governmen~ ~will be converted into an electronic funds transfer (EFT). This means ttle GovemmentYliIi copy the
check and use the account information on ~ to electronically debt the Contracto~s accounl for the amount of the
check. The deM from the Contracto(s account wil usually occur within 24 hours and will be shown on the regular
account statement
The Contractorwill not receive the original check oock. The Government shall destroy the Contractor's original check,
but wi ll keep a copy of it. If the EFT cannot be processed lor technical reasons, Ihe Contractor authorizes the
Government to process the copy in place of the original check
The Contractor shall ensure the order number (Block 4) isctearly visible on all shippiniiservice documents,
containers, and invoices
1052.210-70 CONTRACTOR PUBLICITY {AUG 2011)
The Contractor, or any entity or representative acting on beha~ of the Contractor, stlall nol refer to the equipment or
services fu rnished pursuantlo the provisions of this contract in any ne'IYS release or commercial advertising, or in
connection with any ne'IYS release or commercial advertising. wiIIloot first obtaining explic~ written consent to do so
from the Contracting OffICer. Should any reference to such equipment or services appear in any news release or
commercial a<t.terlising issued by or on behalf of the Contractorwilllout the required consent tile Govemment shall
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consider institution of all remedies availa~e under awlicable law, including 31 U.S.C 333, and lIlis contracl Further,
any violation of lIlis p-ovision may be considered durir.g the evaluaton of past pelformance in future competitively
negotiated acqutsitions.
1052.201-70 CONTRACTING OFFICER'S REPRESENTATIVE (CORI APPOINTMENT AND AUTHORITY (JUN
2012)
(a) The CORs are:
Sarita Frattaroli, 202435-7465, Sarita,Frattarolj@cfpb.goY

Yu Wen Ling, 202435-9451, YuWen.Ling@cfpb.gov
(b) Performance of ;wI\( under lIlis cootract is subject to lIle lechnical direction ofllle COR identifie<1 above,
or a representatrw designated in writing. The lerm technical direclion" indJdes, withoul limitation. direction to lIle
contractor that directs or redirecls the labor effort, shifts the;wl\( belWeen;w1\( areas or locations. andJorfills in
details and otherwise serves to ensure lIlal tasks outlined in the ;wl\(statement are accomplisOOd satisfactorily
33
(c) Technical direction must be within the scope ofllle contractspecification(s)hYo1\( statement The COR
does not have authority to issue technical directioo that
(t) Constitutes a change of assignment or addijionat work outside the contract specification(s)'wol\(
statement;
(2) Constitutes a change as defined in the clause enttled "Char.ges;
(3) In any manner causes an increase or decrease in the contract price, orllle time reC?Jired for contract
performance;
(4) Changes any ofllle terms, coooitions, or specifkation(syYiorl< statement of the contract;
(5) Interferes with lIle contractOi's right to perform under the terms and conditions 01 the contract; or
(6) Directs, supervises or otOOrwise controls the actions ofllle contractOi's employees
(d) Technical direclion may be oral or in writing. The COR must confirm oral direction in writing within five
;wr1<days, with a copy to the Contracting Officer.
(e) The Contractor shall procee<1 prompUywith performance resuHing from the technical direction issued by
lIle COR. If, in the opinion of the contractor, any direction ofllle COR or the designated representative falls within the
limitatons of (c) above, the contractor shall imme<1iately notify the Contracting Officer no later than the beginning of
the next Government ;wI\( day
(f) Failure of the Contractor and the Contractir.g Officer to agree that technical direction is within the scope of
lIle contract shall be subject to the terms 01 the clause entitled Oisputes.
52.217~
OPTION TO EXTEND SERVICE (NOV 1999)
The Government may reC?Jire continood performance of any services within the limits and at the rates specified in the
contract These rates may be adjusted only as a resuH of revisions to prevailir.g laoor rates provided by the Secretary
of Labor. The option provisioo may be exercised more than once, but lIle total extensioo of performance hereunder
shall not exceed 6 months. The Contracting Officer may exercise the option by written notice to the Contractorwithin
30 days before the contract eXpiration date.
52.211--9 OPTION TO EXTEND THE TERM OF THE CONTRACT (MAR 2000)
(a) The Government may extend the term of this contract by wriUen notice to the Contractorwilllin the fina l
30 days of eacll contract period; provided, that the Government grves the Contractor a prelilllnary written notice of its
intent to extend at least 30 days before the contract expires. The preliminary notice does not commit the Government
to an extension.
(b) lIthe Government exercises this option, too extended contract shall be coosidered to include this option
clause
(c) The total duration 01 this contract, including the exercise 01 any options under lilts clause, shall not
exceed !I months.
RIGHTS IN DATA - SPECIAL WORKS (DEC 2007)
(a) Definitions. As used in th is clause-"Data' means recorded information, regardless ofform orthe medium on...mich ij may be recorded. The term includes
technical data and computer software. The term does not include information incidental to cootract administration,
such as financial, administrative, cost or pricing, or management information.
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" Un li m~ed rights" means the rights olthe Govemment to use, disclose, reproduce, prepare derivative works, distribute
copies to the pu ~ ic, and perform publicly and display p.iblicly, in any manner and 10( any purpose, andto have or
perm~ others to do so.
(b) Allocation of Rights.
(1) The Government shall have(i) Unlimited rights in all data delivered under this contract, and in all data first produced in the
performance of this contract. except as provided in paragraph (c) of this clause for copyright
(ii) The right to limit assertion of copyright in data first produced in the performance of this contract
arld to obtain assignment of copyright in that data, in accordance with paragrap'1 (c)(l) of this clause
(iii) The right to lim~ the release and lISe of certain data in accordance with paragral*1 (d) of this
clause
(2) The Contractor shall have, to the extent permission is granted in accordance with paragraph (c)(I ) of this
clause, the right to assert claim to copyright subsisting in data first produced in the performance of th~
contract.
(c) Copyright(1) Data firs! produced in the perfoownoo of this contract.
(i) The Contractor shall not assert or authorize others to assert any claim to copyright subsisting in
any data first produced in the performance of this contract without prior'M'itten permission of the
Contracting Officer. When copyright is asserted, the Contractorshall affix the appropriate copyright
notice of 17 U.S,C. 40t or 402 and acknowledgment of Government sponsorship (including contract
number) to the data when delivered to the Govemment as well as when the data are published or
depos~ed for registration as a published WOtX in the U,S, Copyright Office, The Contractor grants to
the Government and others acting on its behal, a paid-up, nonexclusive, irrevocable, worlctMde
license fo r all delivered data to reproduce, prepare derivative works, distribute copies to the pu~ic.
aoo perform pu~ic ly and display publicly, by or on behalf of the Govemment
(ii) If the Govemment desires to obtain copyright in data first produced in the performance of this
contract and permission has fiat been granted as set forth in paragrapl1 (c)(I)(i) of this clause, the
Contracting Officer shall direct the Contractor to assign (with or without registration), or oliain the
assignment of, the copyright to the Government or its desrgnated assignee
(2) Data not tnt produced in the petformance of/his contract. The Contractor shall not, without piorwritten
permission of the Contracting Officer, incorporate in data delivered under this contract any data not first
produced in the performance of this contract and which contain the copyright nolice of 17 USC. 401 or 402,
unless the Contractor identifies such data and grants to the Government or acquires on its behalf, a license
olthe same scope as set forth in subparagraph (c)(l) of this clause
(d) Release and use restrictions. Except as otherwise specifically provided for in this contract, the Contractor shall not
use, re lease, reproduce, distribute, or publish any data first produced in the performance of this contract, nor authorize
others to do so, without written permission of the Contracting Officer.
(e) Indemnity. The Contractor shall indemnify the Govemment and ~s officers, agents, and employees acting forthe
Government against any liability, including costs and expenses, incurred as the resuH of the violation of trade secrets,
copyrights, or right of privacy or publicity, arising out of the creation, delivery, pu~ ication , or use of any data furnished
urlder this contract; or any libelous or other unlal'lful matter contained in such data. The provisions of this paragraph
do not apply unless the Govemmenl provides notice to the Contractor as soon as practicable of any claim 0( su~,
affords the Contractor an opportunily under applicable laws, rules, or regu lations to participate in the defense of the
claimor sud, and obtains the Contractor's consent to the settlement of any claim orsu~ other than as required by fi nal
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decree of a court of compete nt jurisdiction; and these provisions clo not apply to material furnished 10 the Contractor
by the Governmentand incorporated in data to wflich this clause applies.
PERFORMANCEEVALUATION
This contract is subj-ect to a performance evaluation '<ia The Contractor Performance Reporti1g System (CPARS) at
lWtW.cparscsddisa.mil FolIOYr'ing the end of each contract period and at co ntract completion, a completed
Government evaluation shall be fOlWarded to the Contractor. The Contractor may s ubm~ written comments, if any,
wi\I1in th e time period specified in the evaluation transmittal. The Contractors comments shal be considered " the
issuance of the final evaluatKln document. My disagreement beM'een the parties regardi ng the evaluation shall be
forwarded to the Bureau Chief Procurement Officer (SCPO). The final evaluation of the Contractor's performance is
the decision of the SCPO. A copy of the fi nal performance evaluation rep:lrtwill be sent to the Contractor and to the
Government's past performance data base atWNW,ppirs.gov.
PUBLIC-RELEASE CONTRACT VERSION REQUIREMENT

The contractor agrees to sUOOlit within ten oosiness (10) days from the date the contract is awarded (exclusive of
Satu rdays, Sundays, and federal holidays), a text-based .p:ilfile of the fully executed contract ortask orderwith all
proposed necessary redactions, iocluding redactions of any trade secrets or an y commercial or fi nancial information
that ij believes to be prMleged or confidential business information, forthe purpose of pu~ ic disclosure atthe sole
discretion of the Consumer Financial Protection Bureau (CFPB). The contractor agrees to provide a detailed written
statement specifying the basis for each 01 its Jl(op:lsed redactions, including tM applicable exemj::tion under the
Freedom of Information Act (FOlA), 5 U.S.C. 552, arld, in the case of FOIA Exemption 4, 5 U,S,C. 552(b)(4), shall
demonstrate why the information ts considered to be a trade secret or commercial orfJlancial informaUon that ts
privileged or confidentia l. Information provided by the contractor in resp:ll1se to this contract requirement may itself be
subject to disclosure under the FOIA. The CFPB will carefulty consider all of tM contractor's proposed redactions arld
associated grounds for nondisclosure prior to making a final determination as to what information in the fu lty executed
contract may be prope~y withheld. In the event that the CFPB disagrees with the contractor's suggested redactions,
the CFPB will provide the contractor with notice prior to p:lsting the contract
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52.21Hi

EXECUTIVE ORDERS - COMMERCIAL ITEMS (MAY 2012)
(a) The Contractor shall oorTllly with the folowing Federal Acquisition Regulation (FAR) clauses, lIotlich are
incorporated in this contract by reference, to implement provisions of lawor Executive orcSers applicable 10
acquis~ions of commerc ial ~ems
(1) 52.222-50, Combating Traffickin g in Persons (Feb 2009) (22 U.S,C. 7104(g))
_ Merrlilte I (Aug 2007) of 52.22250 (22 USC 7104!gll
(2) 52.233-3 Protest After Award (AuG 1996) 131 V,SC. 3553),
(3) 52233-4 Applicable Lawlor Breach of Contract Claim (OCT 2(04) (Pub l. 108-77, 108-78)
(b) The Contractor shall coll\'lly with \he FAR clauses in this paragraph (b) thai the Contracting Officer has
indicated as being incorporated in \!1is rontract by reference to inplement provisions of lawol Executive orders
applicable 10 acquisitions of commercial ~ems:
]_ (1) ~ Restrictions on Subcontractor Sales to the Government (Sept 20(6), with Alternate I
(Oct 1995) (41 U.SC 2530 and 10 US.C 2402)
_ (2) ~ Contractor Code of Business Ethics and Conduct (Apr 2010)(Pub. L tl0-252, Title VI,
Chapter 1 (41 US.C. 251 note))
_ (3) ~ Whisflel)ower Protections under the American RecollSf)' and Reinvestment Act of 2009
(June 2010) (Sectioo 1553 of Pub. L. 111-5). (Applies to contracts funded by the American Recovery- and
Re investment Act of 2009,)
] _ (4) 52.204-10, Reporting Executive Compensation and First-Tier Suocontract Awards (FEB 20t2) (pub.
L. 109-282) (31 U,S,C. 6101 note).
_ (5) 2UQill, American Recovery and Reinvestment Act-Reporting Requirements (JuI2010) (Pub. L
111-5).
]_ (6) 52.209--6 Protecting the Government's Interest When Subcontracting with Contractors Debarred,
Suspended, or Proposed for Debarment. (Dec 2010) (31 U,S,C, 6101 note)
_ (7) 52.209-9, Updates of Publicty Available Information Regarding Responsibitity Matters (FEB 2012) (41
USC. 2313).
_ (8) 52.209-10, Prohibition on Contracting with tnverted Domestic Corporations (MAY 2012) (sectioo 738 of
Division C of Pub. L, 11 2-74, section 740 of Division C of Pub. L. 11 I-I 17, section 743 of Division D of Pub. L, 111-8,
and secUon 745 of Division 0 of PUb. L. 110-161)
_ (9) 52,219-3, Notice of HUBZone Set-Aside or Sole-Soorce Award (NOV 20 t 1) (15 U,S,C. 657a).
_ (10) 52.219-4, Notice of Price Evaluation Preference for HUBZone Small Business Concern s (JAN 2011)
(~the offero r elects to waive the preference, ~ shall so indicate in its offer) (15 U.S.C 657a)
_ (11) (Reserved]
_ (12Xi) 52.219-6, NoUce of Total Small Business Set-Aside (NOV 2011) (15 U,S,C. 644).
_ ~i) Merna!e I (NOV 2011)
_ Oii) AHernate II (NOV 2011)
_ (13Xi) 52.219-7, Notice of Partial Small Business Set-Aside (June 2003) (15 US.C. 644)
_ Oil AHernate I (Oct 1995) of 52.219-7
(iii) AHerna!e II (Mar 2004) of 52.219-7
_ (14) 52.219-8, Utilization of Small Business Concerns (Jan 2011) (151J S c. 37(dl!2) and (3))
_ (15Xi) 52.219-9, Small Business Subcontracting Plan (Jan 2011) (15 US.C 637!d)/4l)
_ Oil Mernate I (Oct 2001) of 52.219-9.
(iii) M erna!e II (Oct 2001) 0152.219-9
[IV) Alternate III (Jul2010) of 52,219-9
_ (16) 52.219-13, Notice of Set-Aside of Orders (NOV 2011)(15 US,C. 644(r))
]_ (17) 52,219-14, Limitations on Subcontracting (NOV 2011) (15 U.S.C 637(a)(14)).
_ (18) 52.219-16, Liquidated Damages-Subcontracting Plan (JAN 1999) (15 U.S.C, 637(d)(4XF)(i)).
_ (19Xi) 52.219-23, Notice of Price Evaluation Adjustment for Small Disadvantaged Business Concerns
(OCT 20(8) (10 U,S,C. 2323) (dthe offeror elects to waive th e adjustment, ~ shall so indicate in its offer)
_ Oil Merna!e I (JUNE 2(03) of 52.21923
_ (20) 52.219-25, Small Disadvantaged Business Participation Prtlgram-Oisadvantaged Status and
Reporting
(DEC 2O tO) (Pub. L. 103-355, section 7102, and 10 USC. 2323)
_ (21) 52.219-26, Small Disadvantaged Business Participation Prtlgram-Incentive Subcontracting (OCT
2000) (Pub. L. 103--355, section 7102, and 10 USC. 2323)
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(22) 52.21!1-27, Notice of Service-Disabled Veteran-Owned Small Business Set-Aside (NOV 2011) (15
U,S,C. 657(I).
]_ (23) 52.219-28, Post Award Small Business Program Rerep-esentation (APR 2012) (15 U,S,C.
632(a)(2)).
_ (24) 52.21!1-29, Notice of SeI.Aside for Economicaly [)jsaMntagedWomen..{Nmed Small Business
(EOWOSB) Concerns (APR 2012) (IS U.S,C. 637(m)).
_ (25) 52.21!1-30, Notice of SeI.Asic!e forWomen..(),yned Small Business ('WOSS) Concerns Eligible Under
theWOSB Program (APR 2012) (15 U,S,C. 637(m}).
]_ (26) 52nH Convict Labor (JUNE 2(03) (EO. 11755)
X (27) 52.22219, Child Labor-Cooperation IYith Authorities and Remedies (MAR 2012) (E.O. 13126).
(28) 52.22221 , Prohibition of Segregated Facilities (FEB 1999).
X (29) 5222226, Eq ual Opportunity (MAR 2007) (E.O. t 1246).
(30) 52.22235, Equal Opportunity for Veterans (SEP 2010)(38 U.S.C. 4212).
J_ (31) 52.12236, Affirmative Action forWorl<ers with Disabilities (OCT 2010) (29 USC. 793)
]_ (32) 52.222-37, Employment Reports on Veterans (SEP 2010) (38 U,S.C. 4212)
_ (33) 52.222-40, Notificatioo of Employee Rights Underlhe Natonal Laboo' Relatons Act (DEC 20(0) (E.O.
13496)
_ (34) 52.222-54, Empoyment Eligibility Verificatioo (JAN 2009). (Executive Order (2989), (Nol applicable
10 the acquisition of commerciany available off-the-shelf items or certain other types of commercial items as
prescribed in 22,1803,)
_ (35Xi) 52.223-9, Estimate of Percentage of Recovered Malerial Content for EPA--Designated Ilems
(MAY 2008) (42 U.S.C. 6962{c)(3)(A)(ii)), (Not awlicable to the acquisition of commercially available off-the-shelf
items,)
_ Oil AHernate I (MAY 2008) of 52.223-9 (42 US.C. 6962(i)(2){C)), (Not applicable to the acquisition of
commercially available off-the-shelf Hems,)
(36) 52.223-15, Energy Efficiency in Energy-Consuming Products (DEC 2007) (42 US.c. 8259b).
(37Xi) 52.223-16, IEEE 1680 Standard for the Environmental Assessment of Personal Computer Products
(DEC 20(7) (E.O (3423)
_ Oil AHernale I (DEC 2007) of 52.223-16.
]_ (38) 52.223-18, Encouraging Contractor Policies to Ban Text Messagifig While Oriving (AUG 201 I) (EO.
135(3)
_ (39) 52.225-1 , Buy American Act-8upplies (FEB 2009) (4 1 U.S.C IDa- 10d)
_ (40Xi) 52.225-3, Buy American Act- Free Trade A[1eements-lsraeli Trade Act (MAY 20(2) (41
U,S,C.cIlapter83, 19 U,S,C, 3301 note, 19 U,S,C. 2112 nole, 19 US.C. 3805 note, 19U5.C. 4001 note, Pub. l. 103182, 108-77, 108--78, 108-286, 108-302, 109--53, 109-169, 109-283, 110-138, 112-41 , and 112--42)
_ 0i) AHemate I (MAR 20(2) of 52.225-3
_ (iii) Alternate II (MAR 2012) of 52.225-3
_ (rv) AHernate III (MAR 2012) of 52.225-3.
_ (41) 52.225-5, 52,225-5, Trade Agreements (MAY 2012) (19 U.S.C, 2501 , ef seq., 19 U.S.c. 3301 note).
] _ (42) 52.225-13, Restrictions on Certain Foreign Purchases (JUNE 2008) (E,O.'s, proclamations, and
statutes actninistered by the Office of Foreign Assets Control oflhe Department of the Treasury).
_ (43) 52.226-4, Notice of Disaster or Emergency Area Set-Aside (NOV 2007) (42 US.C. 5150)
_ (44) 52.226-5, Restrictions on Subcoolracting OUtside Disaster or Emergency Area (NOV 2007) (42
US C. 5150).
_ (45) 52.232-29, Terms for FinanCing of Purchases of Commercial Items (FEB 2002) (41 U.Sc. 255{f),
10 U.SC. 2307(f).
(46) 52.232-30, Installment Payments for Commercial Items (OCT 1995) (41 U.S.G. 255(f), 10 US.C
2307{f) _X_ (47) 52.232-33, Payment t7t Electronic Funds Transfer-Central Contractor Registration (OCT 2003)
(31 U.S.c. 3332).
_ (48) 52.232-34, Payment by Electronic Funds Transfer-Other than Central Contraclor Regislrabon
(MAY 1999) (31 U.S.C. 3332).
_ (49) 52.232-36, Payment by Third Party (FEB 2010) (31 U.S.G. 3332).
_ (50) 52.239-1 , Privacy or Security Safeguards (AUG 1996) (5 US.c. 552a)
_ (51 Xi) 52.247.04, Preference for Privalely OMled
_ Oil AHernate I (Apr 2003) of 52.247.04
=x=
=x=
(c) The Contractorshall comply with the FAR clauses in this paragrap'l (c), applicable to commercial
services, thai Itle Contracting OffiCer has indicated as being incorporated in th is contract by reference to impement
pmvisions of lawor Execulive orders applicable to acquisilioos of corrvnercial items
_ (I) 52.222--41, Service Contract Act of 1965, (Nov 2007) (4 1 US.C 351 , el seq)
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(2)52.222-42, Statement of Equivalent Rates for Federal Hires (May 1989) (29 US.C 200 and
- 41 U.S,C. 351, el seq.)

_ (3) 52.222-43, Fair Labor Standards Act and Service Contract Act-Plice AdlllStmen! (MuHipie Year and
Option Contracts) (Sep 2009) 129 U,S,C. 206 and 41 U,SoC 351 e/ seq.).
_ (4) ~ Fair Labor Standards Act and Service Contract Act-Price Adjustment (Sep 2009)
(29 US.C 200 and 41 US.C 351 el seq.)

_ (5) ~ Exemption from Application ofltle Service Contract Act to Contracts for Maintenance,
Ca libration, or Repair of Certain Equip-nenl-Requirements (Nov 2007) (41 USC 351 el seq )
_ (6) ~ Exemption from Application ofl!le Service Contract Act to Contracts for Certain Ser.icesRequ irements (Feb 2009) (41 U.SoC 351 ef seq)
_ (7) 52.226-6 Promoting Excess Food Donation to NonprofitOrganizations (Mar 2009) (Pub. L. 110-247)
_ (8)52.237-11 Accepting ar.d Dispensing of $1 Coin (Seli 2008) (31 U.S.c. 51 12(pl(l lJ
(d) ComplrollerGeneral Examination of Recad. The Contractor shall comply with the p-ovisions of this
paragraph (d) if this contract was awarded using other than sealed bid, is in excess of the simplified acquis~ion
tIlreshold, and ooes not contain the clause at 52.2t5-2, Audit and Records-Negotation.
(1) The Com~rolierGeneral of the Un~ed Stales, or an authorized representative of tile Com~roller General,
shall have actes5 to and right to examine an y of tile Contractor's directty pertinent records inllOlving transactons
related to this contract
(2) The Contractor shall make avaitable at its offices at all reasonable tmes the records, materials, and other
eWience for examinabon, aud~, or reprodoction, until 3 years after fina l payment under this contract orfor any shorter
period specified in FAR Subpart 4.7, Contractor Records Retention, of the other clauses of this contract. If this
contract is completely or partially terminated, the records relating to the war terminated shall be made available for
3 years after any resulting fina l termination settlement Records relating 10 appeals under the disputes clause or 10
I~igation or the settlement of claims arising under or relating to this contract shall be made available until such
appeals, litigation, or claims are finally resolved
(3) As used in this clallSe, records include boo~s, documents, accounting procedures and practices, and
other data, regardless oftype and regardless of form This does not requ ire the Contractorto create or maintain any
record thatlhe Contractor does not maintain in the ordinary course of business or pursuant to a provision of law
(e)(I) Notv.ithstanding tile requirements of the clauses in paragraJils (a), (b), (c), and (d) of this clause, the
Contractor is not required to ftcw down any FAR clause, oIherthan those in paragraphs (e)(I)(i) through (xi) of this
paragraJil in a subconlractforcommercial ~ems. Unless otllerNise indicated below, the extent of lhe flcMr down shall
be as required by the clause---Wl ~ Contractor Code of 8usiness Ethics and Conduct (Apr 2010) (Pub. L. 110-252, Trtle VI,
Chapter 1 (41 USc. 251 note))
(ii) ~ Utilization of Small8usiness Concems (Dec 2010) (15 US.C. 637(d)(2) and (3)), in all
subcontracts Ihat offer further subcontracting opportunities. lIthe subcontract (except subcontracts to small business
concems) exceeds S650,000 (SI ,5 million for construction of any public facility), the subcontractor must include
52.219-8 in iowerter subcontracts that offer subcontracting opportunities
(iii) [Rese~dJ
(iv) 52.222-26 Equal Opportun~y (Mar 2007) (E.O. 11246)
(v)~ Equal OpportunrtyforVeterans (Sep2010) (38lJSC 4212)
(vi) 52.222-36 Affirmative Act~n for Workers with Disab~ities (Oct 2010) (29 U.S.C 793)
(vii) ~ Notrtication of Employee Rights Underlhe Natonal Labor Relatons Act (Dec 2010) (E.O.
13496). FIcMr down requ ired in accordance with paragraph (f) of FAR Clause 52.222-40
(viii) 52.222-41 Service Contract Act of 1965 (Nov2007) (41 USC, 351 el seq.).
(ix) 52.22250, Combating Trafficking in Persons (Feb 2009) (22 U.SC 71041ql)
_A1temate I (Aug 2007) of 52.222-50 (22 U,S.C, 71041q))
(x) 52.222-51 Exem~ion from Application of the Service Contract Act to Conlracts for Maintenance,
calibration, or Repair of Certain Equipment-Requirements (Nov2007) (41 US.C, 351 et seq.).
(xi) ~ Exem~ion from Appication oflhe Service Contract Act to Contracts for Certain Services
Requirements (Feb 2009) (41 U.SC, 351 et seq.)
(xii) 52.22254 Employment Eligillity Verification (JAN 2009).
(xiii) 52.226-ll Promoting Excess Food Donation 10 Nonprof~ Organizations (Mar 2009) (Pub. L 110-247)
Fk:lwdown required in accordance with paragraph (e) of FAR clause~.
(xiv) 52.247-ll4 Preference for Privately ONned U.S.-Flag Commercial Vessels (Feb 2006) (46 US.C
Appx. 1241 (b) and 10 U,S.C. 2631), Fk:lw down requ ired in accordance with paragraph (d) 01 FAR
clause~
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(2)While not requ ired, lIle contractor may include in its subcontracts for commercial nems a minimal number
of add~ional clauses necessary to sabsfy Is contractual obligations
Alternate I (feb 2000). As prescribed in.1.UQ!.(b)(4)(i), delete paragraph (d) from the basic clause, redesignate
paragraph (e) as paragraph (d), and revise the reference to "paragraphs (a), (b), (e), or (d) of this clause" ... the
redesignated paragraph (d) to read "paragraphs (a), (b), and (e) ofltlis clause"
Al/ema/e 1/ (Dec 2010), As pmscribed in l11Q!(b)(4)Oi), substitute thefollov.ing paragraphs (d)(l ) and (e)(I) for
paragraphs (d)(I) and (e)(I ) of the basic clause as fo llows:

(d)(l) The Comptroller General of the Un~ed States, an appropriate Inspector General appointed under section 3 or
8G or the Inspector General Act of 1978 (5 U.S.C. App.), or an authorized representative of either of the foregoing
officials shall have access to and right to-(i) Examine any of the Contractor's or any subcontractors' records that pertain to, and involve transacbons retab ng to,
this contract; and
(ii) tnterview any officer or emptOye regarding such transactions
1'1
(t) Notwithstanding the requirements of the clauses in paragra~s (a), (b), and (c), of this clause, the Contractor is not
req uired to flowdOWTl any FAR clause in a subcontract for commercial items, other than (i) Paragraph (d) of this clause. This paragra~ nows d(Mll'l to all sulxontracts, exce/X the authority of the Inspector
General under paragra~ (d)(I)(i) does not now down; and
(ii) Those clauses listed in this paragaph (e)(l). Unless otherwise indicated below, the extent of the fk::woown shall
be as req uired by the clause-(A) 2UQlli, Contractor Code of Business Ethics and Conduct (Apr 2010) (Pub. L. 110252, Title
VI, Cha/Xer 1 (41lJSC 251 note)).
(8) 2UQill, Wh is~eblower Protections Under the Ameocan Recovery and Reinvestment Act of
2009 (June 2010) (Section 1553 of Pub. l. 111-5)
(C) ~ Utilization of Small Business Concerns (Dec 2010) (15 US.C. 637(dl(2) and 13, in all
subcontracts that oller further subcontracting opportunities. If the subcontract (except subcontracts to small
business concems) exceeds 5650,000 ($1 .5 million for construction 0( any public fac ility), the subcontractor
must include 52.219-8 in lower tier subcontracts that oller subcontracting opportunities
(0) 52.22226 Equal Opportunity (Mar 2(07) (E.O. 11246)
(E) 52.222-35, Equal Opportunity forVelera ns (Sep 2010) (38 U.SC 4212)
(F) ~ Affirmative Action fOo" Workers wth Disablities (Oct 2010) (2911 SC 7931.
(G) 52.222-40, Notification of EmploYe Rights Under the National Labor RelationsAct (Dec 2010)
(E.O. 13496). Flowd(Mll'l required in accordance with paragraph (f) of FAR clause 52.222-40.
(H) 52.22241 Service Contract Act of 1985 (Nov 2007) (4 1 U.S.C 351, et seq)
~) 52.222-50 Combati ng Traffic~in g in Persons (Feb 2009) (22 US.C 7104fg))
(J) 52.22251 Exemption from Application of the Service Contract Act to Contracts for Maintenance,
calibration, or Repair of Certain Equip:nent-Requirements (Nov 2007) (41 U.SC 351 et seq.).
(1<) 52.222-53, Exemption from Application olthe Service Contract Act to Contracts for Certain
Services-Requirements (Feb 2009) (41 lJ.S C 351 eI seq.).
(l) 52.22254, Employment Eligibility Vertication (Jan 2009)
(M) ~ Promoting Excess Food Donation to Nonprofit Orga nizations. (Mar 20(9) (Pub. L
110-247) Flow OO\Yll required in accordance with paragraph (e) of FAR cJause 52.226-6.
(N) ~ Preference for Privatety ONned US.-Flag Commercial Vessels (Feb 2006) (46 lJ S C. Appx. 12411bl
and 10 U.S.C. 2631 ) Flowdown required in accordance with paragraph (d) of FAR clause 52.247-64.
CONTRACT DOCUMENTS EXHIBITS AND An ACHMENTS

DOCUMENT/EXHIBIT! An ACHMENT TITLE
Attachment 1 - Pay Day lending Perfonnance Work Statement
IPPWaiver Form
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Payday Lending Data Project

Performance Work Statement
1.0
OVERVIEW I BACKGROUND. Ol JIiy 21, 2010, President 00000 si9fled the DJdd-Frank Wall
Street Reform aoo Const.mer Protection Act (the "Act'), which created the Coost.mer Finarcial Protection
Bureau (CFPB). Under the Act, part of CFPB's mission is to determine whether and 00w to develop
policies regardirg COrlSlJTlef finardal prodlds am sefVices, such as 5oort-term, small dollar "payday"
loans. Accordirgly, \he Government seeks a contractor to provide an analysis of payday loan usage
accom~nied wrtll irldicalors of borrowers' overall finarK:ial health. This analysis shall incll.de the
provision of data to CFPB detailir,g fXlyday loan usage p:!ltems over a specified period of lime. Payday
loan usage data shall be matched w~h oltler data sources thai track COOSl..fref finarcial well-beirg, su::h
as cred~ reportir19 agercy (eRA) reports
2.0
ms
OBJECTIVE.
data collection will allow CFPB to better understaoo
the distriMoo of payday loan usage patterns amorg oorrowers,
patterns of default on payday loans,
row different levels of usage are correlated w~h charges in other financial measures such as
credit scores, bank accourt status, and overall creditworthiness, ard
row payday loan oorrowers' indcators of cred~ worthiness and overall financial heaHh
compare to similarly-s~uated rouserolds that do not use payday loans
3.0
SCOPE. The cortractor shall provide CFPB a nationally-representative dataset of payday
oorrowers ottaining loans through the internet and slorefrort channels from a diverse variety of payday
lenders. The usage data for 1M sample of oorrowers shall be for a period of at least 12 !T'(lnths from lhe
date a oorrower first is reJXIrted as usirg a payday loan and shall detail the size of loans originated,
whether and when a loan is repaid, renewed, or in default, \t1e overall ntrnber of loans applied for ard
taken by a given oorrower over this tme period, and the time period between loans. Information
obtained through surveys of payday borrowers who self.report their use of payday loans is not
adequate for this analysis.
In add~ion, the cortractor shall match rts payday borrower records wrth addrtional data available th"ough
cred~ rep:xting agencies and other lhird parties to develop a data set that includes other measures of
finarcial well-being such as credrt scores, cred~ ut~lzation and delinquency, and bank account status (ie:
overdrafts andlor involuntary accollll closures) before, during, and after the 12 mon\t1 period of payday
loan usage.
Finally, the contractor shall perform an analysis of similarly s~ualed houselllids that-based on the
contractor's records-are not payday loan borrowers dlJirlg the stlXly lime period. The contractor
shall develop a data set of these Illuserolds thai measures changes in financial wellbeirlgthroug,
cred~ scores, credit utillzation ard delirK1uency, and bank accolJ1t status to compare with the analysis
of payday loan borrowers described atme
The final metlYldology for ths analysis will be developed in consultation w~h CFPB staff and require
the approval of the CFPB's Office of Research
4.0
PERIOD OF PERFORMANCElDELIVERY REQUIRED. The contractor shall electroOcally deliver
a surmlary of data findings and the lXlderlyirg de-de rt ~ied data in a spreadsheet-corrpati~e format to
CFPB w~hin five morths. Dataset will be in a format thai is readily assessa~e through software slh as
SAS or STATA. The contractor shall also be available f()( an additional month to answer clarifyirg and
technical questons from CFPB staff aboU the report and accomparfjing data. Add~ionally, there will be
two option periods in whK:h the Contractor may be required to provide a data refresh at six and 12 rrorths
after the initial report is provided
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BPD-CFP-12-C1.(X))7
334
16
S.O
CONTRACTOR TRAVEL. Contractor will be feqJ ired to \ravel 10 CFPB fo r ore meeti ~ at the
beginning 01 the five month work period of this project to develop a final mett'OOology f()( tI1is data
analysis, in consuHation with CFPB staff
6.0
DATA RIGHTS. The Government has ur" i m~ed rights to all docllTlentsimaterial delivered to the
CFPB IJlder this cootract. All dOOJments and data summaries delivered to the CFPB under this contract
shall be Goverrmefll owned ard are the pwperty of the Government with all rights aoo privileges 01
ownershi.cVcopyrigrl belongirg exclusive~ to the Government. These documents ard materials may rot
be used or sold by the contractor without written permission from the Contracting Officer. All materials
supplied to \he Goverrmert shall be the sole lX"operty of the Govemmerrt and may oot De lISed for any
other purpose. This right does not atrogate any other Government rights.
7.0
QUALITY ASSURANCE (QA). n~ government shall evaluate the contractor's performaoce
lflder the contract in accordarce with ltle standards out1ined in Ire Performance Requirements Sunvnary
(PRS). The PRS defi nes lhe performarce o~ectives, performarce slarxlard, lhe mettod of surveiltarce
and Ire incentivesldisirceriives
8.0
PERFORMANCE REQUIREMENTS SUMMARY (PRS). The contraclor service requiremerlls are
slJl1rTlarized into performarce o~eclives lhal relate directly to mission essential items. The performarce
starxlard il"ieny descrit:oes the minirrum acce.ctab'e levels of service reqlired for each requirement.
These slarxlards are critical to mission success.
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335
17
CfPB stif,knoorg Eccro1:sts

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TlOCfp12<:<))1 i
336
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TlOCfp12<:<))1 i
337
Corelogic Information Solutions Inc.
11. CONTRACTIO CODE
AMENDMENT OF SOUCITATlONIMODIFICATlON OF CONTRACT

2. AMENOMENTIMODIFICATION NO.
13. EFFECTIVE DATE
0002
04/17 /2013
IBPD-RDILLON
6. ISSUED BY
CODE
rA:E
4. REOUISITIONIPURCHASE REO. NO.
7. ADMINISTERED BY Iff albar thlJn Item 6)
CODE
0,
PAGES
PROJECT NO. Iff .ppIicsbIe)
IBPD
Bureau of t he Public Debt

Di vision of Procurement
Avery SF
200 Third Street

Divison of Procurement
Avery 5F
200 Third Street
Attn: R. Dillon
8. NAME AND AOORESS OF CONTRACTOR (No.. _ . """Y, St"....ZIPCOdeI
(x) 9A. AMENDMENT OF SOLICITATION NO
rCORELOGIC INFORMATION SOLUTIONS INC

4 FIRST AMERICAN WAY
SANTA ANA CA 92707-5913
9B. DATED (seE (TEM 11)
lOA MOOIFICATION OF CONTRACT/ORDER NO.
TPD-CFP-12-C-0010
lOB. DATED (SEE ITEM 13)

CODE
IFACILITY CODE
167200760
08/02/2012
11. THIS ITEM UNL APPLIES TO AMENDMENTS OF $OuCllATIONS

DThe_numberedsoiicilal",,~amencledBS ..lforth,,"omI4. 1hehoOJranddaiespocifiedfOlrecoiplofOff...
D~oxIanded,
D~noIox1enc1ed
OffersmUSlllCknowledgerecoiptollhisamendmeni prior 10 1M hoOJr and dale spocifiedinIMsoii:ilalionor as amended, by one oflhe following melhods: (.)By comp~1ing
lIams8andl5,andreltming
_ _ cop~oIIMamendmenl;(b)8yad<nowledg01gleceipi oflhisamendment"'eac!1copyoflMoffersubmilled;or (c)By
separaIe leIIer or leIegtam which includes. ,.,.....,.10 1M solicilation and amendmenl num~. FAILURE OF YOUR ACKNOVvl.EOOEMENT TO BE RECEIVED AT
THE PLACE DESIGNATED FOR THE RECEIPT OF OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION OF YOUR OFFER Kby
vir1IJeoflhisamendmenlyou_lOcf1angeanoller.lreadysubmilled, suchcf1angemaybemadebyl.legramorleller, proyidedeac!1le1egtamorlell.,mal<es,.,.....,.
10 1M soiicilation andlhisamendmanL and ~ received ptiorlOIMopen~g hour and dale spocified
12. ACCOUNnNGAND APPROPRIATION DATA (I/required)
See Schedule
11. THIS ITEM ONLY APPLIES TO MODIACATION OF CONTRACTSIORDERS. IT MODIAES THE CONTRACT/OROER NO. AS DESCRIBED IN ITEM 14,
~ A. ~~&~q~ ~Ef~ ISSUED PURSUANT TO: (Spec;fy .ufhclity) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT
D. ulHER (SpecifyfypeofmooificalionanctaufflclifyJ
E.IMPORTANT:
Contracior
l!Jisnol
Disrequi1edlOsignlhisdooJmenlandrelum
14. DESCRIPTION OF AMENDMENTIMOOlFICATION (Otganized by UCF section headings, including soiicifalionlconfracl subjed matlerwhare feasible.)
The purposes of this modification are to:

1. Appoint Jessica Russell as the Contracting Officer's Representative (COR) .
be reached at 202-435-7771 or via email at Jessica. Rus se ll@cfpb .gov .
2. Appoint Xiaoling Ang as the Alternate COR.

via email at xiaoling.ang@cfpb.gov.
Jessica may
Xiaoling may be reached at 202-435-7686 or
Exc:eples provided her.", alilerm, and c:cnd~~ns of 1M dooJmenl

15A. NAME AND
,.,.,anced in 110m 9A or lOA, as he18lofore changed, 18mains II1changed and in full force and effect
nne OF SIGNER (Type or plinlJ
16A. NAME AND
nne OF CONTRACTING OFFICER (Type or plinl)
JACOB C. OBERLIN
158. CONTRACTORIOFFEROR
15C. DATE SIGNED
__--=-...,...?'Ju
16C. DATE SIGNED
4.17,2013
r~otCMltlCtitr!l~
Pl8'Iiouseditionurwsab~
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STANDARD FORM 30 (REV,

Prescribed by GSA
FAR (48 CFR) 53.243
NSN754O<l1152.s070
338

BUREAU OfTHE PUBLIC DEBT
PARKERSBURG, WV 26106-1328
'2 AugusI2012
Corewgic Information Solutions, Inc.

Attn: Mr. Dave Hun
4 First American Way.
Santa Ana, CA 927075913
Subject: TPD-CFP-12-C-0010
Dear Mr. Hun:
Congratulations! Enclosed is contract number TPD-CFP-12-C-0010 for Loan-Level Mortgage
Dalasets in support oflbe Consumer Financial Protection Bureau (CFPB).
Please review the enclosed contract award and ifin agreement, please complete blocks 30a, 30b
and 30e on Page I of the Standard Form 1449. By signing the SF 1449, you acknowledge and
accept the terms and conditions of this contract. After signing the document, please provide a
copy of the signed form via email to carev.grow@.bpd,treas.gov.
Please nole thaI due to lhe nature of the proposals received, the Indefinite-Delivery IndefiniteQuantity terms and conditions were remo\'ed upon award.
After award, any questions or issues related to this procurement will be handled by the Contract
Administration Branch at contractadministration@bpd.treas.gov. When sending an e-mail to this
address, please include the award number in the subject line of the e-mail.
Ms. Xiaoling Ang has been designated Contracting Officer's Representative (COR) for this
contract. A copy of our letter so designating Ms. Ang is enclosed for your information. It
contains information on her duties and the scope of her authority in this capacity of which you
should be aware. Ms. Ang may be reached at 202-4357686 or via e-mail at
xiaoling.ang@cfpb.gov.
If you have any questions concerning the award, please contact Ms. Carey Gropp, 304-480-8559.
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Enclosures
339
. JI. WI 1.
Q
.
--,--_
.
2'
_ _ SIS.'
A, .. , .... 1<1..11.. II1II

11M G .. , ......
_101100 OC IOU.!
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t:OWoCII:e ~11~ """"lOIS

ttUT
'A'
_
_IIDltM
a.mt1-:t
340
2 of
"
" "
"
~~
SOEru..E<:F~S
"
13
"
.~
~~,
Government Technical POe : Mr . Daniel Grantham

Tel : 202- 435- 7666
E- J:lai l :
d~niel . gr~nth~ro@cf[X> . gov
Suppl emental Term::;, Condition::; and Clause.s are

att~ched
hereto
~nd
Invoice.s are to be
hereby incorporated.
p~id
a.s
from receipt/acceptance .
prcduct Net 30 day.s
Invoice::; ... ill be
.submitted on an annual ba.si.s .

lony que.stion.s related to thi::; a ...ard will be
handled by the Contract Admini.stration Branch at

conte actadmini.str ation@bpj . trea.s . gob .
"''"
.sending an e- mail to thi.s addre.s.s , plea.se include

the award number in the .subject line .
Note : The ,FP amoun t .s identified in each CLIN are
not dependent upon the numbe r of e r PB
~er.s
.since
all querie.s by CFrB u.ser.s ...ill be made again.st

BPD/C,PB .server asset.s .
Credit Card Vendor : NO

Accounting Info :
crp55 77srxXXX - 20 12- 61 000 \ - CFP401 0000- 2513- 0000000
-:o:.x- XX - xxxxxxxxx -xxxxxxxxx-xxxxxxxxx

Period of Perfonnance : 08/02/2012 to 08/01/2017
Continued ...
RECEIVED
OIl<SPECTEO
o ACCEPIED. .<NO COHFOIlMS 10 THE romRACT. EXC8'T AS NOlEO
OF .oJJiHORIZEOGOI'ERNMENI REPPESEN1~TrlE
ll!>
SK;N~TURE
)1.
""'l NG -'OORESS OF AUTff:)RI.ZEO GOVE""":MT REPIlESENT~TO/E
II SHf'NltoIOCR
VOOCIR NltoIOCR
Il1CD.O.1E
~~OUNIVERFE;D
IN PflNlEO NAME .... OI~le OF AUIHQRI.ZEO GOVERliMENI RePflEseNl~TO/E
l~.
lElEPttOIE NJIj(jR Of /<UTHO RI.ZEO GOVERNMENlI'IEPfiESENIATIVE
l~
E-MAL OF AAHOR~EO GOVER""ENT REPRESENT~T"'E
36
31 CHECK NJ_R
P~YI.ENI
~ECTfOR
OCOIoIFtE/
OPAATlAl
OPAAT~
D~'
0'-
I'" WII.lIJCHERNIJMOCR 1"1 pmsy
'j. I CERTfY THISACCOUNT IS CORRECT 00 PflOI'"ER f{)R
P~YMENI
'1. RECEIVEO B"I" (1'00)
llt> ReCEN'DA'(t.ocfl>O.O)
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""_""''''iII1''"' 1k
L:\HEARINGS 2013\04-23 THE CONSUMER FINANCIAL PROTECTION BUREAU S SEMI-
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342
SUPPLEMENTAl TERMS, CONDITIONS AND CLAUSES
SECTION 508 COMPLIANCE

All electronic and information technoklgy (EIT) procured through this contract must meettne applica~e accessibi ~y
standards at 36 CFR 1194, unless an agency exception to this requ irement exists. (36 CFR 1194 implements Section
508 of the Rehabi l~at()n Act of 1973, as amended.
tn accordance w~h the above, in addition to the Technicat Requirements, contraclorsJvendors must ensure thai atl EtT
that they provide either. (1) meets the technicat provisions of the Section 508 Access Board Standards applicable to a
grven procurement (see bebw); or (2) uses designs orteclmobgies as aHemalives to those prescribed in the
specified technical provisions, provided they res uH in substantially equNalent or greater access to and use of a
product for peopte with disabMies
The following standards have been determined to be applical)e to this contract
_ _
1194.21 Software applica~ons and operating systems
L - 1194.22Wetrbased i'ltranet and intemet information and appncations

__
__
__
__
__
__
1194.23 Telecommunications products.

1194.24 Video and muHimedia products
1194.25 SeH-contained, closed products.
1194.25 Desktop arid portable computers
1194.31 Functional Performa nce Criteria
1194.41 Information, Documentation arid Support.
The standards do not requ ire the instaUation of spec~ic accessibility-related software or the attachment of an assislive
technology device, oot merely requ ire that the EIT be compati~e with soch software and devices so that itcan be
made accessible if so required by the agency in the future,'

The contractor agrees to subm~, within ten business (10) days from the date the contract is awarded (exclusrve of
Saturdays, Sundays, and federal holidays), a text-based .p::fffile of the fully executed contract with all proposed
necessary redactions, including redactions of any trade secrets or any commercial or financial information thatl
believes to be privileged or confidential business information, for the purpose of pu~ic disclosure at the sole discretion
of the Consumer Financial Protection Bureau (CFPBj. The contractor agrees to provide a detailed written statement
specifying the basis fo r each of its proposed redactions, l1cluding the applicable exemption under the Freedomof
Information Act (FOtA). 5 U.SC. 552, and, in the case of FOIA Exemption 4, 5 U.S.C 552(b)(4), shall
demonstrate why the info rmation is considered to be a trade secret or commercial or financial information that is
privileged or confidentia l. Information provided by the contractor in response to this contract requirement may itself be
subject to disclosure under the FOIA. The CFPB will careful y consider the entire contractor's proposed redactions
and associated grounds for nondisclosure prior to making a final determination as to what information in the fully
executed contract may be property withheld. In the event that the CFPB disagrees with the contractor's suggested
redactions, the CFPB will provide the contractor with notice prior to posting the contract.
SOFTWARE FEDERAL DESKTOP CORE CONFIGURATION (FDCC)

AI software which is designed to run on Windows Vista or XP desktops must fu nction without modification to th e
Federal Desktop Core Configuration (FOCC) security configurations developed by the National lnsmute of Standards
aoo Technology (NIST), the Department of Defense (DoD) and the Department 01 Homeland SeCUrly (DHS).
Software and hardware products that are designed to operate in environments other than the FDCC desldop must
have a standard configuration guide published on the NIST website, or the vendor must supply a recommended
configuration guide for all configurable security settings
52.212-4
CONTRACT TERMS AND CONDITIONS - COMMERCIAL ITEMS (fEB 2012)
(a) Inspection/Acceptance. The Contractor shan only tender for acceptance those ~ems that conform 10 the
requirements of this contract. The Government reserves the right to inspect or test any supplies or services
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343
that have been tendered for accelXance. The Govemment may requ re refXIiror replacement of
nonconforming suppUes or reperformance of nonconforming services at no increase in contract price. If
repair/replacement or reperformance will not correct the defects or is not possible, the Govemment may
seek an equ~able p1ce reduction or adequate consideration for accelXance of nonconforming supplies or
services, The Govemment must exercise ~s post-acceptance rights(1) Within a reasonable time after the defect was discovered or should have been discovered; and
(2) Before any substanlial change occurs in the condition of the item, unless the change is due to the
defect in the ijem
(b) ASSignment. The Contractor or its assignee may assign its rights to receive payment due as a result of
performance of this contract to a tenk, trust company, or other financing institution, including any Federal lending
agency in accordance with the Assignmentof Claims Act (31 USC. 3727). HO'M'!ver, wtlen a third party makes
payment (e.g., use of the Governmentwide commercial purchase card), lt1e Contractor may not assign its rights to
receive payment under this contract
(c) Changes . Changes in the terms and condibons of lt1is contract may be made only by written agreement of
lt1e partis.
(d) Disputes. This contract is subject to lt1e Contract Disputes Act of 1978, as amended (41 U,S.C. 601-613).
Failure of lt1e parties to this contract to reach agreement on any request for equitable adjllStment, claim, appeal or
action ariSing under or relating to this contract shall be a dispute to be resot.oed in accordance with the clause at FAR
52.233-1, Disputes, ...mich is incorporated herein by reference. The Contractor shall proceed diligently with
performance of this contract, pending final resoluton of any dispute arising under the contract.
(e) Definitions. The clause at FAR 52.202-1 , Oefinnions, is incorporated herein by reference.
(D Excusable delays. The Contractorshall be liable for defauH unless nonperformance is callSed by an
occurrence beyond the reasonable control of the Contractor and without its fault or negligence such as, acts of God or
the public enemy, acts of the Govemment in either its sovereign or contraclllal capacity, fires, floods, epidemics,
quarantine restrictions, strikes, unustJalty severe 'M'!ather, and delays of common carriers. The Contractorshal notify
the Contracting Officer il writing as soon as ~ is reasonably possible after the commencement of any excusable
delay, setting forth the full particulars in connection therewith, shall remedy such occurrence with all reasonable
dispatch, and shall promptly gr.re written notice to lt1e Contracting Officer of the cessation of such occurrence.
(g) Invoice. The Contractor shaDsubmn an original invoke and three copies (or electronic invoice, if authorized,)
to the address designated in the contract to receive invoices, An invoice must include-(i) Name and address o(the Contractor,
(ii) Invoice date and number,
(iii) Contract number, contract line ~em number and, if applicable, the order number,
(iv) Description, quantity, unit of measure, un~ price and extended p1ce of the items delivered;
(v) Shipping number and date of shipment, including the bill of lading number and 'M'!ight of shipment d shipped
(vi) Terms of any discount for prompt payment offered;
(viij Name and address 01 official to wtlom payment is to be sent;
(viii) Name, Utle, and phone number of person to be notdied in event of defective invoice; and
(bc:) Taxpayer Ident~ication Number (TIN). The Contractor shall include its TIN only if requ i'ed else...mere in this
contract.
(x) Electronic funds transfer (EFn banking information
(A) The Contractor shal include EFT banking inforrnation only if required elsev.f1ere in this contract.
(B) II EFT tenking information is not requred to be on the ilvoice, in orderforthe invoice to be a proper
ill\lOice, the Contractor shall have submitted correct EFT banking information in accordance with the app~cable
solicitation provision, contract clause (e.g., 52.232-33, Payment by Electronic Funds Transfer--Central Contractor
Ragistration, or 52, 232-34, Payment by Electronic Funds Transler-.Qtherthan Central Contractor Registration), or
applicable agency procedures
(C) EFT banking information is not req uired if the Govemment waived lIle requirement to pay by EFT
(2) Ill\IOices will be handled in accordance with the Prompt Payment Act (31 US.C. 3903) and Office of
Management and Budget (OMB) prompt payment regulations al5 CFR 1315
(h) Patent indemnity. The Contractor shall indemnify the Government and its officers, employees and agents
against liaDlity, including costs, for actual or alleged direct or contributory infringement of, or inducement to infringe,
any United States or foreign patent trademark or copyright arising out o(the performance of this contract provided
the Contractor is reasonably noMed of such claims and proceedings.
(i) Payment, (1) Items accepted. Payment shall be made for items accepted by lt1e Government that have been
delivered to the delivery destinations set forth in lIlis contract.
(2) Promptpayment, The Government wi ll make payment in accordance with lt1e Prompt Payment Act (31
U,S,C. 3903) and Office of Management and Budget (OMS) prompt pay regu lations at 5 CFR 1315.
(3) Electronic Funds Transfer (EFT) If the Govemment makes payment by EFT, see 52.212-5(b) for the
appropriate EFT clause.
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(4) Discount. In connection with any discount offered for early payment, time shall be computed from the date of
the invoice. For the purpose of computing the discount earned, payment shall be considered to have been made on
the date which appears on the payment check or the specified payment date ~ an electronic funds transfer payment is
made
(5) Overpayments. If the Contractor becomes aware of a duplicate contractfmancing or rwo;ce payment or that
the Government has otherwise overpak! on a contract financing or invoice payment, the Contractor shall(i) Remit the overpayment amount to the payment office cited in the contract along with a description of the
overpayment including the(A) Circumstances of the overpayment (e.g., duplicate payment, erroneous paymen~ liquidation errors,
date(s) 01 overpayment):
(B) Affected contract number and delivery order number, if applica~e;
(C) Affected contract line ~em or sub~ne ~em , ~ applica~e; and
(D) Contractor frint of contact
(ii) Provide a copy olthe remittance and supporting documentation to the Contracting Officer.
(6) Interest.
(i) All amounts that become payable by the Contractorto the Government under this contract Shall bear
simple interest from the date due until paid unless paid wiI!1in 30 days 01 becoming due. The interest rate shall be the
interest rate esta~ished by the Secretary of the Treasury as provided in Section 611 of the Contract Disputes Act of
1978 (Public law 95-563), ...mich is applicable to the period in which the amount becomes due, as provided in (i)(6)(v)
of this clause, and then at the rate applicable for each sixmonth period as fixed by the Secretary until the amount is
paid
(ii) The Government may issue a demand for payment to the Cootractor u~n finding a debt is due under the
contract
(iii) Fila/decisions. The Contracting Officerwill issue a final decision as required by lll1.1~(A) The Contracting Officer and the Contractor are unable to reach agreement on the exisleoce or amount
of a deb! within 30 days;
(B) The Contractor faits to liquidate a debt p<eviously demanded by the Contracting Officer within the
time~ne specified in the demand for payment unless the amounts were not repaid because the Contractor has
requested an inslallme!1t payment agreement or
(C) The Contractor requests a defermenl of collection on a debt previously demanded by the Cootracting
Officer (see 32.607-2).
(iv) If a demand for payment was previously issued for the debt, the demand for payment included in the final
decisKln shal identify Ihe same due dale as the original demand for payment.
(v) Amounts shall be due at the earliest of the following dates
(6) The date olthe first lYritten demand for payment including any demand for payment resutting from a
defauK termination
(vi) The interest charge sllall be computed for the actual number of calendar days involved beginning on the
doo date and ending on-(A) The date on wI1ich the designated office receives payment from the Contractor;
(6) The date 01 issuance of a Govemment check to the Contractor from which an amount otherwise
payable has been withheld as a credit against the contract debt; or
(C) The date on ...mieh an amount withheld and applied 10 Ihe contract debt would otherwise have become
(vii) The interest charge made under this clause may be reduced under the procedures prescribed ., 32.608J. of the Federal Acquis~ion Regulation in effect on the dale olthis contract
U) Riskof loss. Unless the contract specifically provides otherwise, risk of loss or damage 10 the supplies
pmvided under this contract shall remain with the Contractor until, and shall pass to the Government u~n
(1) Delivery of the suppli~ to a carrier, if trans~rtation is I.o.b. origin; or
(2) Delivery of the supplies to the Government at the destination spec~ied in the contrac~ ~ transportabon is
I.o.b. destination
(k) Taxes. The contract price includes all awlicable Federal, State, and kx:al taxes and duties.
(I) Temlinalkm for fhe Government's convenience. The Government reserves the right to terminate this contract,
or any part hereof, for ~s sole convenience. In the event of such termination, the Contractorshal immediately stop all
woll< hereunder and shal immediately cause any and all of its suppliers and subcontractors to cease work. Subject to
the terms of this contract, the Contractor shall be paid a percentage of the contract price reflectin g the percentage of
the woll< performed prior to the notice of termination, plis reasonable charges the Contractor can demonstrate to the
satisfaction of the Government using its standard record keeping system, have resufted from the termination. The
Contractor shall not be required to comply with the cost accounting standards orcontractcosl principles for this
purpose. This paragraph does not give the Government any right to audit the Contractors records. The Contractor
sha~ not be paid lor any woll< performed or costs incurred ...mich reasonabty coukl have been avoided.
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(m) Terminafion forcause. The Government may terminate this contract, or any part hereof, for cause in tile
event of any default by the Contractor, or if the Contractorfa~s to comply with any cootract terms and conditions, or
fails to provide the Government upon request with adequate assurances of future performance. In tile event of
termination for cause, the Government shatl not be liable to the Contractorfor any amount for suppUes or services fIOt
accepted, and the Contractor shaD be liable to the Government for any and all rights and remedies .crovided by law. If
ij is determined that the Govemment improperly terminated tIlis contract for default, such termination shall be deemed
a termination for convenience.
(n) Tille. Unless specified elsel'h1ere in tIlis contract, title to items furnished undertllis contract shall pass to the
Government upon acceptance, regardless of when orwhere tile Govemment takes p,ysical possession
(0) Warranty. The Contractorwarrants and impnes that tile ~ems delivered hereunder are mercllantable and fil
for use for the particular purpose described in this contracl
(p) Limitation of liability. Except as otherwise provided by an express warranty, the Contractorwill not be liable
to the Government for consequential damages resuHing from any defect or deficiencies in accepted items
(q) Other compliances. The Contractor shall comply with al appicable Federal. State and local lav.s, executive
orders, rules and regulations applicable to its performance under this contract.
(r) Compliance with laws unique to Govemmentcontracfs, The Contractor agrees to comply with 31 U.SC. 1352
relating to limitations on the use of appropriated funds to influence certain Federal contracts: 18 U.S.C, 431 relating to
officials not to benem: 40 USC, 3701 et seq" Contract Wolk Hours and Safety Standards Act: 41 USC. 5158 Anti
Kickback Act of 1986: ~ and 10 U,S.C. 2409 relating to whistieblawer protections: 49 U.S,C, 40118 Fly
American; and 41 U.SC. 423 relating to procurement integrity
(s) QrJerof precedence. My inconsistencies in this sok:nation or contract shall be resolved by giving
precedence in the follOl'o1ng order
(1) The schedule of supplies/servees
(2) The Assignments, Disputes, Payments, Invoice, Other Compliances, alld Compliance with Lav.s
Unique to Govemment Contracts paragraphs of this clause
(3) The dause at52,2125
(4) Addenda to this solicitation orcontract, including any license agreements for computer software
(5) Solicitabon provisions if this is a solicitation.
(6) Other paragraphs of this clause
(7) The Standard Form 1449.
(9) The spec~icalion
(t) Central Contractor Registratioo (CCR)
(1) Unless exempted t1f an addendum to this contract, the Contractor is responsit::le during performance and
through final payment of any contract forthe accuracy and completeness of the data within the CCR database. alld for
any liability resutting from the Govemment's reliance on inaccurate orincomplete data. To remain registered in the
CCR database aflerthe innial registratioo, the Contractor is required to reviewalld update on an annual basis from
tile date of initial registration or subsequent updates its information in tile CCR database to ensure n is current,
accurate and complete Updating information in the CCR does not alter the terms and conditions of this contract and
is not a subst~utefor a propeny executed contractual document.
(2j(i) If a Contractor has legally changed its business name, "doing business as" name, ordivisioo name
(l'h1ichever is shown on the contract), or has transferred the assets used i:\ performing tile contract, but has not
completed the necessary requirements regarding novation and change~name agreements in FAR Subpart 42.12,
the Contractor shall provide the resp:!nsible Contracting Officer a minimum of one business day's written not~K:ation
of its intention to tAl change tile name in the CCR database; (B) comply with the requirements of Subpart 42, 12: and
(C) agree in writing to the timeline and procedures specihed by the responsible Contracting Officer. The Contractor
must provide with the notification sulli::ient documentation 10 support the legally changed name
(ii) If the Contractorfails to compy with the requirements of paragraph (tX2Ki) of this clause, or fails to
perform the agreement at paragrap, (tX2)(i)(C) of this dause, and. in the absence of a .crope~y executed novation or
change-<lf-name agreement the CCR information that shows the Contractor to be otherthan the Contractor indicated
in the contract will be consklered to be incorrect I:1formation within the meaning of the "Suspension of Paymenr
paragrap, of the electronic funds transfer (EFT) clause oftllis contract
(3) The Contractor shal not cIlange tile name or address for EFT payments or manual payments, as
appropriate, in the CCR record to reflect an assignee for the purpose of assignment of claims (see Subpart 32.8,
Assignment of Claims). Assignees shal be separately registered in the CCR database. lnformabon provided to the
Contractor's CCR record that indicates payments, including those made by EFT, to an uttimate recipent other than
that Contractor will be considered to be incorrect information within the meaning of the "SUspension of paymenr
paragrap, of the EFT dause of this contract
(4) Offerors and Contractors /My obtain information on registration and annual confirmation requirements via
CCR accessed through htt,OJ.lAVlfW.acquisifkln.govor by cal~ng P!88-2272423 or 2699615757
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ADDENDUM TO 52,2124, CONTRACT TERMS AND CONDITIONS - COMMERCIAL ITEMS(FEB 2012)

Internet Payment Platform OPP) is a secure web-based electronic invoicing and payment information service available
to all Federal agencies and their supplier by the U,S. Treasur(s Financial Management Service. IPP allows Federal
agencies and theirsuppliers to exchange electronic purchase orders, blanket POS, in~ces, and payment nformation
in one easy to access web portal. This service is Iree 01 charge to government agencies and their suppliers, including
services and support
The prelerred method 101 invoicing is IIlrough IPP. The IPP webs~e address is https:lfwMy, ipp,gov, Contractor
assistance 'Nith enrollment can be obtained by contacting the Bureau of the Public Debfs IPP Team at 3044808000,
OpUon 7 or IPP Production Help desk via email ipooroup@bosJrb,orgorphone(866)973-3131 .
II the Contractor is unable to utilize IPP lor submitting payment requests, invoices may be submitted electronically to
lIle email address shown in Bbck 18a, page 1 after completin g the IPP Wa'Ner Form and subrrltting ~ via emaill0
contractadministration@OO:l.treasgov. Adobe Acrobat Portable Document Format (PDF) and Microsoft Word are
acceptable lonnats. Invoices shall contain the inlormation requi red in FAR 52.2124(g)
Under this contract, lIle fomo'Ning documents are required to be submitted as an attachment to the invoice
None applicable
PAYMENT AND INVOICE QUESTIONS

For payment and l1voice quesUons, go to https'lfwMy,loogov or contact the Accountirog Services DMsion at (304)
480-8000 option 7 or via ema~ at AccountsPayable@bpd,tleas,gov
OVERPAYMENTS
In accordance with 52.2124 section (i) 5 Overpayments Accounts Receivable Conversion of Check Payments to
EFT II the Contractor sends the Government a check 10 remedy duplicate contra ct financi ng or an overpayment by
lIle government ij 'Nill be converted into an electronic fu nds transfer (EFT). This means the Government 'Nill copy the
check and use the account inlormation on ~ to electronically debt the Contracto(s account fOI the amount of the
check. The deMlrom lIle Contractor's account 'Nil usually occur within 24 hours and 'Nill be shown on the regular
account statement
The Contractor'Nili not rece'Ne the original check tack. The Government shall destroy the Co ntracto ~s original check,
but 'Nill keep a copy of it II the EFT cannot be processed lor technical reasons, the Contractor authorizes the
Government to process the copy in place of the onginal check
MARKING OF SHIPMENTS
The Contractor shall ensure the contract number and delivery order number is clearly visible on al shippingfservice
documents, containers, and invoices
1052.20170
CONTRACTING OFFICER'S REPRESENTATIVE (COR) APPOINTMENT AND AUTHORITY(JUN

2012)
(a) The COR is identified in the SF 1449, Bbck 20

(b) Performance 01 war\( under this contract is subject to the technical direction of the COR identified above,
or a representat'Ne designated in writing. The tenn 'technical direction" ilcludes, without lim~ation , direction to the
contractor that directs or redirects the labor ellort, shifts the war\( between war\( areas or k>caUons, and'orlins in
details and otherwise serves to ensure that tasks outlined in the war\( sta tement are accompished sa tisfactorily
(c) Technical direction must be within the scope of the contractspecification(s)/work statement The COR
does not have authority to issue technical direction that
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(1) Gonstftutes a change of assignment or additional work outside the contract specilication(s}lwork
statement
(2) Gonst~utes a change as defined in the clause enMed 'Changes~
(3) In any manner causes an increase or decrease in the conlract price, orilla time required for contract
performance;
(4) Changes any ol\!le terms, conditions, or speciflCation(s}lwork statement of the contract;
(5) Interferes with tM contracto(s right to perform under the terms and conditions of the contract or
(6) Directs, supervises or otherwise controls the actions of the contracto(s employees
(d) Technical direction may be omlor in writing. The COR must confirm oral direction in writing within five
wo rkdays, wi\!l a copy to the Contracting Officer
(e) The Contractor sha. proceed prompUywith performance resuHing from the lecllnical direction issued by
the COR. If, in the opinion olthe contractor, any direction of the COR or the designated representative falls within the
limitations of (c) above,the conlractor shall immediately notify the Contracting Officer no later than the beginning 01
the next Govemmentwork day
(I) Failure of the Contractor and the Conlracting Officerto agree that technical direction is within tIle scope of
the contract shall be subject to Ihe terms of the clause ent~led Oisputes.'
1052.210-70
CONTRACTOR PUBLICITY (AUG 2011)
The Contractor, or any entity or representative acting on behaJ of the Contractor, shall not refer to Ihe equipment or
services fum ished pursuant to the provisions of this contract in any ne'IYS release or commertial advertising, or in
connection with any news release or commercial advertising, without fi rst ottaining eJ(pIicit written consent 10 do so
from tIle Contracting OffICer, Should any reference to such equipment or services appear in any news release or
commercial advertising issued by or on behalf of the Contraclorwithout the requ ired con sent,the Government shall
consider institution of all remedies available under applicable law, including 31 U,S,C. 333, and this contract, Further,
any Wllation of this provision may be considered during the evaluaUon of past perlormance in future compeUtively
negotiated acquisitions.
52.217~
The Govemment may require continUd performance of any services within the imits and at the rates specified in the
contract These rates may be adjUsted only as a resuft of revisions to prevailing labor rates PfcMded by the Secretary
of labor. The option provision may be exercised IOOre \!lan once, but the total extension of performance hereunder
shaft not exceed 6 months. The Contracting Officer may exercise the option by written notice to the Contractor within
30 calendar days before the contract expiration date
52.217-9
OPTION TO EXTEND THE TERM OF THE CONTRACT {MAR 2000)
(a) The Government may extend the term of this contract by written notice to tIle Contractorwi\!lin the final
30 calendar days of each contract period; Pfovided that the Government gives the Contractor a preliminary written
notice of its intent to extend at least 30 calendar days before the contract expres The preliminary notice does not
comm~ the Government to an extension.
(b) lIthe Governmentexercises this o~ion, the eJ(tendedcontract shall be considered to include this option
clause
(c) The total duration of this contract, including the exercise 01 any options under this clause, shall nol
exceed five (5) years.
CONTRACT TERM
The period 01 performance is a 12'lOOnth base period and foor (4) t2'lOOnth OIXiOn periods.
PAST PERFORMANCE EVALUATION

This contract is subject to a performance evaluation via The Contractor Performance Reporting System (CPARS) at
WHN.cpars,csd,disa,mil, Following the end 01 each contract period and at contract completon, a completed
Government evaluation shall be forwarded to tIle Contractor. The Contractor may submit written comments, ~ any,
within the time period specified in the evaluation lransmiUal The Contractor's comments shall be considered in the
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issuance of the final evaluation document Any disagreement between the parties rega rding the evaluation shall be
forwarded 10 Ihe Bureau Chief Procurement Officer (SCPO) The final evaluation of the Conlractor's pertormance is
the deciskln 01 the SCPO. A copy of the final pertonnance evalualion report will be senl lo the Contractor and 10 Ihe
Govemment"s past pertormance database atVNNIppirs.gov

EXECUTIVE ORDERS - COMMERCLAL ITEMS (APR 2012)
52.212-5
(a) The Contractor shall complyw~h the folkJ,ving Federal Acquisition Regulation (FAR) ctauses, ...mieh are
incorporated in this contract by reference, to implemenl provisions of law or Executrve orders applicable 10
acquis~ion s of commercial ~ems
(1) 5?n2-5O, Combating TraffiCking in Persons (Feb 2009) m U.S.C. 7104(gl)
_ AlterMte I (Aug 2(07) of 52.222-50 (22 U.S C. 71041ql).
(2) 52.233-3 Protest After Award (AuG 1996) (31 U.S.C. 3553),
(3) 52.233-4 Applicable Lawlor Breach of Contract Claim (OcT 2004) (Pub L. 108-77. 108-78)
(b) The Contractor shall colTJjlly with the FAA clauses in this paragraph (b) that the Contracti ng Off(:er has
indicated as being incorporated in this contract by relerence to implement provisions ollawor Executive orders
applicable to acquisitions of commercial ~ems:
]_ (1) 52.203-6, Restrictions on Sulx:ontractor Sales to the Government (Sept 2(06), with Alternate I
(Oct 1995) (41 U.S.C. 2530 and 10 US.C. 24021.
_ (2) ~ Contractor Code ol8usiflss Ethics and Conduct (Apr 2(10) (Pub. L. 110-252, Title VI,
Chapter 1 (41 U.S.C. 251 note))
_ (3) ~ Whisfle!)OY/ef Protections under the American Recovery and Reinvestment Act 01 2009
(June 2010) (Section 1553 of PUb. l. 111-5). (Applies to contracts funded by the American Recovery and
]_ (4) 52.204-10, Reporting Executrve Compensation and First-Tier Sulx:ontract Awards (FEB 2012) (Pub
L. 109-282) (31 U.S.C. 6101 note)
_ (5) 52.204-11 American Recovery and Reinvestment Act-Reporting Requirements (JuI2010) (Pub. l.
111-5).
]_ (6) 52.209-6 Protecting the Government's Interest When Subcontracting with Contractors Debarred,
Suspended, or Proposed for Debarment (Dec 2010) (31 USC 6101 note)
]_ (7) 52.209-9, Updates 01 Publicly Available InfOfmaton Regarding Responsibility Matters (FEB 2012) (41
US C. 2313).
_ (8) 52.209-10, Prohibition on ContractinglYith Inverted Domestic Corporations (section 740 of Division C
of Pub. l. 111-117, section 743 of Oivision D 01 Pub.l 111-8, and section 745 of Division 0 of Pub. l 110-161).
(9) 52.2193, Notice 01 HUBZone Set-Aside or Sole-Source Award (NOV 2011) (15 U.S.C. 657a)
(IO) 52.219-4, Notice of Price Evaluation Preference IOf HUBZone Small Business Concerns (JAN 2011)
(~the ofIerorelecls to waive the preference, ~ shall so indicate i'l its offer) (15 USC 657a)
_ (11) (Reserved]
_ (12)(i) 52.219.0, Notice of Total Small Business Set-Aside (NOV 2011) (15 U.S.C. 644).
_ Oi) Mema!e I (NOV 2011)
_ Qii) A~emate II (NOV 2011).
_ (13)(i) 52.219-7, Notice of Partial Small Business Set-Aside (June 2003) (15 USC 644)
_ Oi)Memate I (Oct 1995) 0152.219-7.
_ Qii) A~emate II (Mar 2004) of 52.219-7
]_ (14) 52.219-8, Utilization of Small Business Concerns (
(3))
_ (15)(i) 52.219-9, Small Business Subcontracting Plan (
_ (ii) Anemale I (Oct 20(1) of52.219-9.
_ (iii) Altemate II (OcI200l) of 52.219-9
(iv) Allernafe //I (JuI2010) of 52.2199
_ (16) 52.219-13, Notice of Set-Aside a/Orders (NOV 2011)(15 U.S.C. 644(r))
_ (17) 52.219-14, limitations on Subcontracting (NOV 2011) (15 U.S.C. 637(a)(14))
_ (18) 52.219-16,liquidated Damages-Subcontracti'lg Plan (JAN 1999) (15 U.S.C. 637(d)(4XFXi))
_ (19Xi) 52.219-23, Notice of Price Evaluation Adjustment fo r Small Oisadvantaged Business Concerns
(OCT 2008) (10 U.S.C. 2323) (d the offeror elects to warve the adjuslrl1ent, ~ sI1al so indicate in its offer).
_ Qi) Memate I (JUNE 2(03) of 52.219-23.
_ (20) 52.21lJ-25, Smal Disadlrantaged Business Participation Program-Disadvantaged Status and
Reporting
(DEC 2010) (Pub. L. 103-355, section 7102, and 10 USC. 2323)
(21) 52.219-26, Smal Disadlrantaged Business Participation Program-lrlCenlive Subcontracting (OCT
2000) (PUb. L 103-355, section 7102, and 10 USC. 2323)
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_ (22) 52.219-27, Notice of Service-Oisabled Veleran-Owned Small Business Set-Aside (NOV 201 1) (15
USC.657(f)
]_ (23) 52,219-28, 52.219-28, PostAward Small Business Program Rerepresentation (APR 2012) (15
USC.632(aX2))
_ (24) 52.219-29, Notice of Set-Aside for Economically DisadvantagedWomen-O.vned Small Business
(EOWOSB) Concerns (APR 2(12) (15 U.S.C. 637(m)).
_ (25) 52.219-30, Notice of Set-Aside forWomen-ONned Small8'Jsiness ('WOSB) Concerns Eligible Under
tile WOSB Program (APR 2012) (15 USC. 637(m))
_X_ (26) 52.222-3, Convict labor (JUNE 2003) (E.O. 11755).
]_ (27) 5222219, Child labor-Cooperation.,.,;th Authorities and Remedies (MAR 2012) (E.O 13126)
] _ (28) 52.222-21 , ProhiMion of Segregated Facilities (FEB 1999).
]_ (29) 52,22226, Equal Opportunrty (MAR 2007) (EO. 11246)
X (30) 52.222-35, Equal OpportunrtyforVeterans (SEP 2010)(38 U,S.C 4212)
=X= (31) 52,222-36, Affirmative Action for Workers with Disabilrties (OCT 2(10) (29 U,S,C. 793)
X (32) 52,222-37, Employment Reports on Veterans (SEP 2010) (38 US,C, 4212).
=X= (33) 52222-40, Notification of Employee Rights Under the National labor Relations Act (DEC 2010)
(EO 13496)
_ (34) 52.222-54, Employment EligiDlity Verification (JAN 2(09). (Executive Order 12989). (Not applicable
to the acquis~ion of commerciany available off-{he-she! items or certain other types of commercial items as
prescribed in 22,1803,)
_ (35)(i) 52.223-9, Estimate of Percentage of Recovered Material Content for EPA-Designated Items
(MAY 2008) (42 US.C 6962(c)(3)(AXii)) (Not applicable to the acqu~ition of commercially available off-the-she~
ijems,)
_ (ii) AHem ale I (MAY 2(08) of 52.223--9 (42 US.C. 6962(i)(2){C)). (Not applicable 10 Ihe acquis~ion of
commercially available off-tile-shelf items.)
_ (36) 52.223--15, Energy Efficiency in Energy-Consuming Products (DEC 2(07) (42 U.SC. 8259b)
_ (37)(i) 52.223-16, IEEE 1680 Standard for the Environmental Assessmentof Personal ComJllller Products
(DEC 2(07) (E.O. 13423).
_ (ii) AHem ale I (DEC 2007) of 52.223--16.
_X_ (38) 52.223-18, Encouraging Contractor Policies to Ban Text Messaging While Oriving (AUG 2(11) (E.O.
13513)
_ (39) 52.225-1 , Buy American Act-8upplies (FEB 2(09) (41 U.S.C, 10a-IOd).
_ (40)(i) 52.225-3, Buy American Act-free Trade Agreements-lsraeli Trade Act (MAR 2(12) (4t US.C
chapter83, 19 U.S.C 3301 nole, 19 U,S,C 2112 nole, 19 U.S.C 3805 note, 19 U.S.C 4001 nole, PUb. L 103-- 182,
Pub. L 108-77, t08-78, 108-286, t08-302, 109-53, t09-169, 109-283, 110-138, and Pub, l 112-41)
(ii) Afternale I (MAR 2012) of 52.225-3
(iii) Alternate II (MAR 2012) of 52.225-3.
(rv) AHem ale III (MAR 2012) of 52.225-3
(41) 52.225-5, Trade Agreements (MAR 2(12) (19 U,S.C. 2501 , et seq" 19 US.C, 3301 note).
]_ (42) 52.225-t3, RestrttioflS on Certain Foreign Purchases (JUNE 2(08) (E,O, 's, proclamations, and
statutes adml:listered by the Office of Foreign Assets Control of the Department oltlle Treasury).
_ (43) 52.226-4, Notice of Disaster or Emergency Area Set-Aside (NOV 2007) (42 U,S.C. 5150)
_ (44) 52.2265, Restricbons on Subcontracting Outside Disasler or Emergency Area (NOV 2(07) (42
U,S,C. 5150).
_ (45) 52.232-29, Terms for Financl:lg of Purc hases of Commercial Items (FEB 2(02) (41 USC 255(1),
10 U.S.C, 2307(f))
_ (46) 52.232-30, Installment Payments for Commercial Items (OCT 1995) (41 U.S.C. 255(f), 10 USC
2307(f))
J_ (47) 52.232-33, Payment by Electronic Funds Transfer-Central Contractor Registration (OCT 2003)
(31 U.Sc. 3332)
_ (48) 52.232-34, Payment by Electronic Funds Transfer-Otherthan Central Contractor Registration
(MAY 1999) (31 US.C 3332)
_ (49) 52.232-36, Payment by Third Party (FEB 2010) (31 U.S.C. 3332)
_ (50) 52.239-1 , Privacy or Security Safeguards (AUG 1996) (5 U,S,C, 552a).
_ (51)(i) 52.247~4, Preference for Privately OWned
_ (ii) Altemate I (Apr 2003) of 52.247-64
(c) The Contractorshall comply with the FAR clauses in this paragraph (c), applicable to commercial
services, that \I1e Contracting Officer has indicated as being incorporated in th ~ contract by reference to implement
provisions of lawor Executive orders applicable to acquisitions of commercial ~ems
_ (1) 52,222-41 , Service Contracl Act of 1965, (Nov 2(07) (4 1 US.C, 351, el seq.).
=
=
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_ (2) 52.222-42, Statement of Equivalent Rates for Federal Hires (May 1989) (29 U.S.C 206 and
41 U.SC 351, at seq.)
_ (3) 52 222-43, Fair labor Slandards Act and Service Contract Act-Plice Adjustmenl (Multiple Year and
Option Contracts) (Sap 2009) (29 USC. 206 and 41 USC 351 at seq.)
_ (4) 52.222-44, Fa~ labor Standards Act and Service Contract Act-PMce AdjllSlmenl (Sep 2009)
129 U,S.C, 200 and 41 U,S.C, 351 et seq.)
_ (5) ~ Exemption from Appijcabon of tMe SelVice Contract Act to Contracts for Maintenance,
Calibration, or Repair of Certain Equipment-Requirements (Nov 2007) (41 USC. 351 et seq.)
_ (6) 52.222-53, Exemption from Application of the SelVice Contract Act to Contracts for Certal'1 Ser'licesRequirements (Feb 2009) (41 U.S.Q. 351 e/ seq,)
_ (7) 52.226- Prorrotng Excess Food Donation to NonprofitOrganizations (Mar2009) (Pub. l. t 10-247)
_ (8) 52,237-1 1 Accepting and Dispensing of $t Coin (Sept 2008) (31 U,S,C. 5t 12Ip){t))
(d) ComplrolJerGeneral Examinalt)n of Rerord. The Contractor shall comply with the provisions of this
paragraph (d) nthis contract was awarded using other than sealed bid, is in excess of the simplified acquisition
threshold, and ooes not contain the clause at 52.215-2, Audit and Records-Negotation.
(1) The ComptroOerGeneral of the United States, or an authorized representative of the ComptroOer General,
sha~ have access to and right to examine any of the Contractor's directly pertinent records invoMIl9 transactions
related to this contract
(2) The Contractor shall make available at its offices at all reasonable times the records, materials, and other
evidence for examination, audit, or reproduction, unt~ 3 years after final payment under this contract orfor any shorter
period specified in FAR Subpart 4.7, Contractor Records Retention, of the other clauses of this contract. If this
contract is completely or partially terminated, the records relating to the mrk terminated shall be made available for
3 years after any resulting final termination settlement Records relating to appeals under tMe disputes clause or to
litigation or the settlement of claims arising under or relating to this contract shall be made available until such
appeals, litigation, or claims are finally resolved
other data, regardless oftype and regardless of form. This does not require the Contractorto create or maintain any
record that the Contractor does not maintain in ttle ordinary course of business or pursuant to a jXOVision of law.
(e)(I) Notwithstanding the requi'ements of tMe clauses in paragraphs (a), (b), (c), and (d) of this clause, the
Contractor is not requ ired to flow dClMl any FAA clause, other than those in paragraphs (e)(I)(i) through (xi) of this
paragraph in a subcontract for commercial ~ems. Unless otherwise indicated below, the extent of the now OOwt1 shal
be as req uired by the clauseW)52.203-13, Contractor Code of 8usiness Eth(:s and Conduct (Apr 2010) (Pub. l. 110-252, Title VI,
Chapter 1 (41lJ.SC.251 note)).
(ii) 52.2t9-8 utilization of SmaD 8usiness Concerns (Dec 2010) (15 U.S.Q. S371d)(21 and (3)), in all
subcontracts that offer further subcontracting opportunities. lIthe subcontract (except subcontracts to smal rosiness
concems) exceeds $650,000 ($1 .5 million fo r construction of any public facility), the subcontractor must include
52.219-8 in lower tier subcontracts thatoffet subcontracting opportunities
(iii) [Reserved)
(iv) 52.222-26 Equal Opportunity (Mar 2007) (E.O. 11246).
(v) 52.222-35, Equal Opportunity lor Veterans (Sep 2010) (38 U.S,C, 4212),
(vi) 52.222-36 Affirmative Actkln for Workers with Disabnmes (Oct 2010) (29 U.S.C. 793).
(vii) 52.222-40 Notification of Employee Rights Under the Nationallalxlr Relatons Act (Dec 2010) (E.O.
13496). Flow down required in accordance with paragraph (f) 01 FAA clause 52.222-40
(vii) 52.222-41 Service Contract Act of 1965 (Nov2007) (41 USC. 351 el seq.)
fix) 52.222-50, Combating Trafficking in Persons (Feb 2009) (22 U.SC. 7104(9))
_AHernate I (Aug 2007) of 52.222-50 (22 USC. 71041gl).
(x) 52.222-51, Exemption from Appication of the Ser'lice ContractAct to Contracts lor Maintenance,
calibration, or Repair of Certain Equipment-Requirements (Nov 2007) (41 U.S.C 351 et seq)
(xi) ~, Exemf:(ion from Appication of the Ser'lice Contract Act to Contracts for Certain Ser'licesRequirements (Feb 2009) (41 US.C 351 et seq.)
(xii) 52.222-54, Employment EligiD I ~y Verif(:ation (JAN 2009)
(xiii) 52.226- Promoting Excess Food Donation to Nonprof~Organizatio n s (Mar 2009) (Pub. l. 110-247)
FlowdClMl required in accordance with paragraph (e) of FAA clause 52.226-6.
(xiv) 52.247-{'4 Preference for Privately Owned U,S,-Flag Commercial Vessels (Feb 2006) (46 U.S,C.
Appx. 124 t(b) and 10 U.S.C. 2S31)' Flow down required in accordance with paragraj:t (d) of FAR
clause~
(2)While not required, the contractor may include in its subcontracts lor commercial items a minimal number
of additional clauses necessary to sabsfy IS contractual obligations
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351
CONTRACT DOCUMENTS, EXHIBITS, AND ATTACHMENTS

DOCUMENTlEXHIBITI ATTACHMENT TITLE
License Agreement
Technical Requirements
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MASHR L Ic[ NSE AGRWENT
This Master License Agreement is entered irto between CoreLogic Sohtions, LLC, a California limited liability company
('-core Logic'), and The Bureau of the Public Debt rBPD"), on behalf of the Consumer Finaoce PrCl:ection Bureau("CFPB"
and with BDP, '-cltltomerl (collectil'ely, the "Parties; or indil'idually, a "Pan;"). This Master License Agreement is
efTectil'e upon the date of laS! sigmture CEfTectivc Date')
For good and I'aluable consideration, the receipt and adequacy of which art hereby acknowledged, the Panies agree as
follows:
I. Definitions
Unless the oonteXi of a proI'ision herein otherwise requires, words importing the singular slIIU include the plural and I'ice
The words -inclwe,~ "inclllles" or "incl~" shall mean inclllle \I;tOOUllimitation, includes without limitation or
inclOOing without limitation, As \tied in this Agreement (as dermed below), the following terms have particular meanings as
defmed below,
\'e1'3a,
1.1
~Agrefmfnt" means this IIlaster License Agreement, together with all related statements of work (each a "SO\V"'),
exhibits, ordersand amendments-
L2 ~ConfKlfnti31 Information" means (i) information disclosed by a Party rel:Jling to the Services (as defined below),
product development strategy aoo activity, marketi~ strategy, corporate assessments aoo strategic plans, either present or
futae; pricing, firraneial and statistical information, accounting information, identity of and inform:Jlion regardi~ the Parties
to this Agreement, suppliers, employees, im'estOiS, or customers; software, SOO"ce code, >":I'stems, processes, designs,
schematics, methods, techniques, algorithms, formulac, inventions, diSCOHries, policies, guidelines, procedures, practices,
disputes or litigation; (ii) other confKlel1ial, proprietary ortrade secret inform:Jlion disclosed by that Party that is idenlified in
writing as such at the time of its disclosure; (iii) other confidential proprietary or trade seaet information disclosed by that
Party; (iv) information relating to that Part~'s employees, contractors or customers, such as social security number
,'erifiC3tion which, if released, weuld cause an unlawful or actienable im'asion of privacy; (\') the terms of this Agreement;
and (I'i) any compilation or summary of inform:Jlion or data that is itself confidenlial
1J ~nd US('r~ m~ans, if sp.-cifically authori~d in the Permitted Applications of a particular SOW, an iOOil'idual or
entity determined b)' Customer to haI'e a lrgitimate business need to use the Services or Customer'S products that incorporate
or rely on the Services. End Users shall only access the Services or Customer's products on a restricted basis, as authorized
in the SOW, using an assigned password or other SOOJrity mechanism to ~vent umuthoriud access.
1,4 ~PermiUed Affiliatf" means, if specifiC3lly authorized in the Permitted Application'; of a particular SOW, an entity
identifIed in the Permitted Applications of a particular SOW as authorized to access the Services.
1.5
~Permitttd
Applications" means the aul00..ized use of the Services set fonh in the a[lllicable SOW
1.6 ~Permitted Proussor" means, if ~cifically autOOrized in the Permitted Applicationsof a particular SOW, an entity
independent of Customer that processes data on behalf of Customer aoo that 1m been approved in adl'an;;e in writing by
CoreLogic to prol'ide processing services using the Services set forth in sIK:h SOW.
1.7
~Permitttd
Users" means, if applicable, End Users, Permilled Aff~iates, and Permilled Processors collectil"ely.
1.8 ~Sel"l'ices" means the software applications, models, anal~1ic:s, data, reports, scores, images and any applicable user
manwls and any cther sm'ices rrovided by CoreLogic to Customer as ~cified in each SOW. The Services include any
oomctions, bug fL>:eS, enhancements, updates or other modifIcations to the Services
2. Agree ment Structure
This Agreemel1 contains terms and ooooitioru appliC3ble to all SOWs When fully executed by authorized signatoriesefthe
Parties, each SOW sets forth the specific Services, delivery metOOds, fees, Permitted AppliC3tions and any ether terms
appliC3ble tothe ~cific Services provided under such SOW aoo attaches to this Agreement
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11
Ucrnst Grant. Subject to the terms and conditions of this Agreemen~ CoreLogic grants to Customer a oonexclusil-e, non-uWlSferable, limited license to use the Services set forth in each '!I)W solely for the Permitted Applications
for each of the Sen'ices. There are no implied licenses Wlder this Agreement, Wld any rights not expressly granted to
Customer are reserwd by Core Logic for its own use and benefit
12
Ucrnst Restric lions. Customer represeltS and warmnts to CoreLogic that it shall comply, Wld ensure thai its
Permitted Users comply, with the following:
(a) Custom~r shall oot use the St"'ices for purposes other than the Permitted Applications and shall ensure
compliance w~h such terms by its Permitu:d U5eJS, if applicable
(b) Unless expressly authorized in the Permitted Applications: (i) with the exception of Permitted U5eJS, Customer
shaU not share the StIVices with any parent, subsidiary, affiliate or oIher third party, irw::hxling any third parties involved in
any joint Hnture or joint marketing arrangements with Customer; and (iiij Cll';tomer shall nOl use or store the SeIVices
outside the United States
(e) Unless expressly aulloized in the Permitted Applications, Customer shall not: (D disclose, use, dissemina\1:,
reproduce or publish any portion of the SJvices in any manner or permit the same; (ii) comingle, process or combine any
portion of the Services or permit any portion of the Services to be comingled, processed or combined \I;th OIher data or
software from any OIll!:r source; (iii) allow acx:ess to the Sen'ices through any terminals located ootside of Cll';tomer"s
operations or facil~ies; (iv) use the Services to create, emarw::e or structure any dataoose for resale or distribtdion; (v)
redistrib\1e the Sen'ices or Customer"S products O'ICr the Internet; or (vi) use the Services to mate models, anal}1ics,
derr.,atin products or other derivative works.
(d) Notwithstanding anything to the contrary, the Parties un:lerstand and agree that the information provided by the
federal Goverrunent in response to a consumer's request on til!: IRS Form 4~T, the Social Stcurity Administration form
SSA-89 or any similar Government request form constitutes ''transaction and experience information" as described in Section
603(dX2XA)(i) of the Fair Cn:dit Reporting Act, 15 USC. 1681 et seq. (the MFCRAj, and oot consumer report
information as defined in FCRA Section 6OJ(d). Moreover, the Parties mderstand and agree that, when CcreLogic provides
Services to Customer by delivering the information obtained from the federal Government pursuant to such forms, CoreLogic
acts only as a oonduit bo!tween the federal Governmert and ClNomer with respect to such information and that CoreLogic
does not assemble or evalwte stK:h information for the pwpose of providing the information to Customer or to any other third
party, Customer shall not use the &rvices: (i) as a factor in establishing an iOOividml's eligibility for credi~ insurWlce, or
emplo}ment; (ii) in connection with a determination of an indil'iduars eligibility for a license or other benefit grnnted by a
gOI'emmental authority; (iiD in connection with lDlderwriting individml insuraoce; or (iv) in any way that would cause the
&rvices to constitute a ~consWl1er report" lDlder the FCRA or similar ~tUle, or by any other autlx>r~y having jurisdiction
over the Parties,
(e) Customer shall not use the Services in Wly way that: (i) infringes CoreLogic's or any third party's copyright,
patenl, trademark, trade secret or other intellectual property or rrlllrietary rights or rights of plblicity or privacy; (ii) violates
any law, statute, ordinaoce orregulation; or (iii) is defamatory, trade libelous, mJa\\fully threatening or unlawfully harassing,
If the Permitted Applications include direct marketing use, Customer shall comply with any applicable non-solicitation laws
and regulatiOllS.
(0 Customer shan (i) obtain any necessary licenses, certificates, permits, approvals or other aUiOOrizations
required by federal, state or local statute, law or regulation applicable to Customer's use of the Sen'ices; and (ii) only allow
authJrized End Users to access the SeIVices. Customer shall maintain the confidentiality of any usemames and passwords
issued by CoreLogic and Customer shall not permit =names or passwords to be shared amongst its employees. CoreLogic
may prohibit COOCIlITt11l sessions with the same username and password
(g) Customer shall nOl disassemble, decompile, manipulate or rmrse engineer CoreLogic's Confidential
Informatiooor any portion of the Services. Cuslomer shall take all necessary steps to prel'ent IUlaUthoriZed use or disclosure
or disassembly, decompiling, manipulation (I meNe engineering of CoreLogic's Confidertial Information or Wly portion of
the Services.
(11) All prodoct names set forth in the SOWs are registered or common law trademarks or smice marks
(coHectil'ely "Trademarks") of CoreLogic or its affiliates or data providers and no right (I liceme to use the Trademarks is
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granted WIder this Agreement. Except as may be authorized in prior IITiting by CoreLogic, Customer shall not use the
Trademarks in any ool'ertising or promotioml material nor shall Customer disclose Cor~Logic as a data Xl\lce to any third
party, except that such. disclosures may be made as required by federal, state or local goI'emmeJ1
regulations. Notwith.standir.@theal)(we,unlessexpresslyauthcrizedinanapplicableSOW,Customershllloot remove, alter
or obscure any Trademarks or proprietaJy notices cootained in tile Services or other materials prm'ided by CoreLogic, and 10
the extent any Trndemarb appear in tile Services, Cllitomer shill have a limited license to use such Trademwks in
acoordaoce \\;tII the terms and conditions of th.is Agreement and solely as they appear in tile Services.
~,
Oeher.' of Dnta and Fonnal
Customer acknowledges that tile anilability of data elements in the Services yaries substantially from arealO{lrea, aoo
circumstances may exist or arise which ~event CoreLogic from providing such data or achiel'ing complete repres.:ntaliCfl of
all data elements in tho: Services. Notwithstanding anythi~ to the contrary, CoreLogjc may limit or discontinue tile provision
of the Services for geographic locations where (i) CoreLogic is restricted by rules, regulations, laws or gOl'emmental entities;
(ii) CoreLogic has Ifu:ontinued the collection of data; or (iii) CoreLogic is prohibited by third party providers. CoreLogic
and Customer shall renegotiate the Fees (as &fined below) in good faith according to the prevailing pricing models if
CoreLogic matelially modifies the content or growaphic cO\'erage of the Services pr(Wided to Customer. Customer
acknowledges and acceptS Con:Logic's use of offsrore or onshtte subcontractors to provide the Services. CoreLogjc may
discontinuo::, upgrade or clIange the produ;;tion, support, &lil'el}' and maintenance of any Sen'ices ifCoreLogic develops an
upgraded version or OIherwise can no longer PflWi<!e such Services
5.~
5.1
Feu. Customer shall pay CoreLogic the fees sc:t forth in each SOW ("Fees"') in accordance with the Prompt Pay
Act At the end of each CoreLogic billing cycle, CoreLogic may invoice Customer for all Fees iocurred by Customtl during
s~h billi~ cyck:
5,2
T~xes, Fees are exclusin of sales, use, ad I'alorem, persomJ propffiy, and other taxes, which are the responsibility
of Customer. CoreLogic shall charge Customer applicabk: sales tax; prol'Kled, howmr, trot Customer may provide
CoreLogic witll a resak: or exemption certificate in order to ooIify CoreLogic how to appropriately inl'oice Customer for any
applicablela"(eS, Cu&omer shall me all other ta,!(e5.
6, Reoor1ingj Audits [Intentiomllyomitted.]
7.
T~rm' T~ rminalion
7.1
Term ~nd Termination. The term of this /l-iaster LiceJ"6e Agreement commences on the Effectil'e Dolte ard
continues until all SOWs are terminated. The term of each SOW is as specified in each S\K!h. SOW
7.2
meets of Trrminalion. Upon termination of this Agreement or a SOW, allliceJ"6e rights granted by CoreLogic to
Customer pursuant to tile Agreement or such. SOW terminate and Customer shall pay CoreLogic in full for all Services
accessed or delil'ered
7J
Rfllirn or IHstruction of ~btn ials. Within 15 days of termination of this Agreemenl or a SOW by either Party,
wtless otherwise provided in a SOW and if requo::sted by CoreLogic, Customer shall: (i) return all Services and CoreLogic's
Confidential Information (including all copies of tile same) (the "Materials"") to CoreLogic at the address set forth on the
signatW'e page of this AgreemeJ1 or as specified by CoreLogic and cenify by an officer of Customer trot Customer 1m
retwned all Materials; or (iD destroy alllluterials and certify by an officer of Customer trot such Materials hal'e been
destroyed. If such Materials ate not returned or destroyed in accordance with the above, Customer shall proI'ide CoreLogic
or its designee access to Customer's premises for the retriel'Sl of all such Materials, and Customer shall pay the actual costs
as reawnably incWTed by CoreLogic to retriel'e such Materials. Customer shall contirwe paying CoreLogic fees ordinarily
and reasonably charged by CoreLogic for the Services after the termination of this Agreement. Wltil such. time as Customer
relllm'; to Con:Logic or destroys such. IIhterials
8, Third Part" Ust
Customer warrants that its Permined Users' use of the Services shall be in compliance with this Agreement and Customer
shall be liable for any use of the Services by its I'.!rmitted Users. Customer shall not pr01lide or cause to be proI'ided the
Sen'ices to a processor. unless it is exrx-essly al.fhorized in the Permitted Applicalions of a SOW or otherwise authorized in
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355
writing in advance by CoreLogic and th: processor enters into an agreement agreeing to be bowld by th: tenns of this
Agreemenl and th: applicable SOW, naming CoreLogic as an express third ~l1y bereficiary and ackoowledging that the
processor shall only use th: So!l\'ices to fulfill its processing obligation to Customer.
9, Co nfi lit nti alitl'
9,1.
Obligatio ns. Neither Party shall use, dissem inate, reproduu orpo!rmit to be used, disseminated or reproductd, or in
any way disclcu the other Party's Confidential Information to any person or entity except as required by law or as
specifically po!rmitted in this Agreement Abselll prior written COI\'leIU of the other Pany, each Party shall disclose
Confidential Information only to those of its employees and independ~nt cootractOiS who hal'e p-tviously agreed to be: bouOO
by the terms aoo coooitionsofthis AgreemelU and its in-house and outside legal counsel who need to know slk:h information
Each Party shlll treat all Confid~nt ial Information disclosed to it in connection lIith this Agreement as strictly confidential
using commercially reasonable measures at least Iual to those USl:d by su::h Party with respeer to its own Confidential
Information
9.2
hr~ pt io ns. The restrictions on use aM disclosure of Confidential Information sct forth in Seaion 9.1 shlll not
apply to any particular Confidential Information when and to the extent that the Confidential Information (i) is or becomes
generally available to the [)lblic thr~ 00 fault of the r:eiving Party (or anyone acting on its behaU); (ii) was previously
rightfully koollTI to tt.:: reeeiving Party free of any obligation to keep it oonfidential; (iii) is subsequently disclosed to tt.::
receiving Party by a third party who may rightfully transfer and disclose the information w~hOUl restriction and free of any
obligation to keep it oonfidential; (iv) is independently del-eloped by the receiving Party or a third party witlllut reference or
access to the disclosing Party's Conlidential lnformation; or (v) is ott.::rwise agreed upon by the: Parties not to be subject to
the restrictions sct forth in Seetion 9. 1. The receiving Party may disclose Confidential Information if required to do so as a
maner of law, regulation or cem orda, provided that (i) the receiving Party shan use all reasoroble efforts to provide the
disclosing Party with at leasllO days prior notice of su;;h disc1osure, (ii) the reeeiving Party shall disclose only that portion of
the Confidential Information that is legally required to be: furnished, and (iii) the receiving Party shall use reasonable efforts
to se~k from the party to which the information must be disclosed oonfid~nt ial treatment of the disclosed Confidential
Information Notwithstand~ that portions of the Sel\'ices may be: deril'td in woole or in part from publicly available
SOU'"Ce$, the Sen'ices and any of CoreLogic's databases used in deriving the Services are )X"oprictary, copyrighted and trade
secrets of CoreLogic and, for the avoidance of doutt, the reSITictions on use aM disclosure of the: Services are not subjeet to
the exceptions oontained in this Section9.2
10.
Clln~umfr
Prilarv
Customer ackoowledges the Services may oontain public reeord data and trot this information may be cOI"lSidered sensitive
information by some consumers. Customer shan oot: (a) broadcast or othelV/ise make pub~c the name, a<klress or other
information abou! an individual cOllSwner; or (b) utilize in any manner the name, mailing aciaess, e-mail address or
telephone number of a consumer that is designated in any results obtained \IS~ the So!l\'ices as request~ protection from
so~citation
11. CortLogic In<ie mnifirutionj Di~l aim ers; Injunrlion

Intellrctual Proptrty Indemnification CoreLogic shall indemnify, defend and hold Customer harmless from all
II.I
third party claims, losses, liabilities, costs and expenses auributable to any allegalion of intellectual property infringement in
the United States arising OUI of this Agreement, pro~ided that: (D Customer gil'es CoreLogic prompt written notice of any
soch allegation, The Department of Justice shall represent the gOl'emmenl against any such claims in accordance with 28
U.SC. 516. Notllithstanding the abo~e, this warrant)' does not apply and CoreLogic shall ha\'e 00 obligation 10 indemnify
Customer if an allegation arises from the combination or use of the Sell' ices with any ott.!r software, data, or materials not
fumis[);!d by CoreLogic, if modifications are made 10 the SIVices without CoreLogic's written autOOrization, or if the
Sen-ices are used in violation of the terms and conditions of this Agreement THIS SECTION SETS FORTH
CORELQGIC"S El\!JlRE LIABILITY TO CUSTm,fER AND cusrm,fER'S SOLE REtlffiDIES WITH RESPEcr TO
ANY INTELLEcrUAL PROPERTY THIRD PARTY CLAIMS
I L2
Infrin gement. If in Core Logic's sole discretion the Services violate a third party's intellectual property rights,
CoreLogic may: (i) procure the right for Customer 10 cOr1inue using the Services; (ii) modify the Services to reMer them no
10!l';er subject 10 any s\ICh claim or action; or (iiD replace the So!rvices lIith equally suitable, fWlctionally equil'alenl, noninfringing sen-ices.
11.3
Umitations on Ser. icrs. [Intentionally omitted]
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IIA Warranty and Disdaimer. CoreLogic warrWllS that the Services are merchantable and frt for the panicular
purpose described in each SOw. CORELCXiIC DISCLAThiS ANY OTHER WARRANTY OR REPRESENTATION OF
ANY KIl\1D, EITHER EXPRESS OR Il...IPUED.
11.5 Injundion. Customer acknowledges that the Services are valwble commercial )l"000cts, the development of which
ulI'olved til! expenditure of substantial time Wld money, Any \'iolation of the Permined Applications or Corelogic's
intellectual property righlSshall be governed by 28 U.S.C. 1498.
12. CortLogic's Umitation or Lia bility
NOTWITHSTANDING ANYTHING TO THE CONTR.6..RY IN THIS AGREEMTh'T, EXCLUDING CORELOOICS

INTELLECTUAL PROPERTY [NDEMNlFlCATlON OBLIGATIONS CONTAlNED IN PARAGRAPH 11. 1 ABOVE,
CORELCXiIC"S TOTAL LIABILITY AND aJSTO!l{I;R"S EXCLUSIVE REMEDY UNDER OR RELATED TO THIS
AGREEMENT IS LIMITED TO DIRECT MONEY DAMAGES NOT EXCEEDING THE GREATER OF THE AMOm.,rr
PAID BY CUSTOllffiR TO CORELCXiIC DURlNG THE THREE MONTHS PRECED[NG THE CLAIM OR $10,00)
THIS W.fIT [S CUMULATIVE AND ALL PAY!I'IENTS UNDER THIS AGREEMENT ARE AGGREGATED TO
CALCULATE SATISFACTION OF THE UlIfiT THE EXISTENCE OF MULTIPLE CLAIMS OOES NOT ENLARGE
THE LIMIT NOTWITHSTilJIDING ANYTHING TO THE CONTRARY IN THIS AGREElIiENT, CORELOOIC
SHALL HAVE NO LIABILITY UNDER OR IN ANY WAY RELATED TO THIS AGREEMENT FOR ANY LOSS OF
PROFIT OR REVENUE OR FOR ANY CONSEQUENT[AL, [},'OIRECT, INClD8HAL, SPECIAL, pm.,1JTlVE, OR
"'\'EMl'LARY DAMAGE$, EVEN [F CORELOO[C IS AWARE OF THE FOSSIBILITY OF SUCH LOSS OR
DAM,AGES
U. Customer's Indfmnifkation nn\(:ntionallyomined,j
14. Gtnerllf
Prolisio n~
14.1 Federa[ Acquisition Regu[ations, Federal Acquisition Regulations ('FAR") Sections 52.2 12 1, 52.212-4, 52.2123 and 52.212-5 are hereby incO!pOl1lted
14.2. Agency. The Parties adnowledge drat this is a business relationship based on the e.xpress proI'isions of this
Agreement and 00 partnership, joint wllure, agency, fiduciary or employment relationship is interoed or created by this
Agreeme .... Neither Party is the legal representative or agent of, nor lias the power or right 10 obligate, dired or supervise til!
daily affairs of the other Party, 800 neitll!r Party 0011 act or r~)l"esent or hold itself out as soch. The rigJus, duties,
obligations aoo liabilities of the Parties shan be semal and not joint, each party being ilXIividw1ly responsible only for its
obligations as set forth in this Agreemert
14.3 Smrability. If Wly of the provisions of this Agreemelll becomes invalid, illegal or menforceable in any respect
W1der Wly law, til! validity, legality and enforceability of the remaining provisions shaU not in Wly way be affected or
impaired.
14.4 Wainl'. Any waim is only valid to the extent expressly set forth in writing. No waiver by eitll!r Party of any
breach by til! other Party of Wl)' of til! prol'isions of this Agreemert is deemed a waiver of Wly preceding or succeeding
breach of til! same or Wly other provision
14.5 Sul"linl The following sections suryive termination of this Agreement and continue in full effect W"ltil fully
satisfied: 3.2 (License Restrictions); 5 (Fees); 6 (Reporting; Audits); 7.2 (Effects ofTermination); 7.3 (Return or Destruction
of Materials); 8 (Third Party Use); 9 (Confidentiality); \0 (Consumer PriYacy);; 11.4 (Disclaimer); 12 (CortLogic's
Limitation of Liability);; Wld 14 (General Prol'isions)
14.6
Emution. This Agreement or Wly SOW rna)' be executed in Wly number of counterparts, each of which is deemed
Wl original, Wld all taken together constitute one and the same instrumenl. If this Agreement is executed in counterparts, no
signatOl)' is bound Wltil all Parties have duly execlled this Agreement and all Parties ha\'e recei\'ed a fully executed
Agreement. Any signature transmitted by facsimile or email (in .pd~ .tif, .jpeg, or a similar format), or a pootocopy of such
transmission, is deemed 10 constirute tl".! original signature of such Party 10 this Agreement. The indil'iduals signing below
reiXesent that they are allhorized to do so by and onbeha[f of the Party for woom the)' are signing.
14.7 Gonrning Law; Forum; Jury Trial; Attorneys' Fen. The interpretalion and construc\ion of this Agreemenl is
governed by the lawsofthe United States
VerDate Nov 24 2008
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hgdofS
357
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IU
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AII!c..leD.t N'd!).cr tilt)' Jball wipl 01' QUSfo:r IhiI A~ On'\1 tljho III cbUp:Iou u ~ ApcOllftll
'IIitA:I~t !he prior wri1Ia consiliI o(the OtMr tarty, 'IIfIich 1haIJ 1101 bot 1WtI\I000ty whhllt\d, 'OIIdil. 0\' okby<d. Any
IIIIlIIhori=4 lilSifm'4/OI' tnllll{ershall bcvok!. l1I1s
WNil .... d 11_ co IhI bdlefit aftbt Pm u6lhtit
mplrMpMlillcdJ~Md lICt"IiltOd us",..
14.9
",f'WMII{
14.10 HtdeH. Adj 8Il11ce ot o6et CIO/MIalClbl nq,irtd 01' perNItollaia IMr Apmca! UslClidttdy a/YeG If
okli.cnd .. pmoc. ICmI ~)' OAt ofd\o! fGlIo".nc 1Mbods: (I) ktlllllle 01' (b) CO!n..erdany ~ ~ SUYiI:t
,.;th Indi,,!erpabnitia. Nolit.cIlll CIatJoI\\CfIlliU be UIltlll kaddrwor Dllli1e lot.Vt.4in 1IK:1i~ 1tAcs. Ntldtu
"lillo'
FIrst AnIcrican Wl'J. $inti Au, CIIIilmrit. 9l107"Fr.ctiadlc (7U) 216-6S~. *1 10 !h.
of 1M f~ btIow, willi. cow I~ Coulotlc', ~1 " Il1o IiIm, Iddrew mlJttd A\Ieatlon; !ApI
MySIICb 1ICI.iec00~b ~proptrlydo!lvndllof~)IIIc_patoDaIIy4eliwn4. Q~ WI!
br IicaiIrak, or (iii) GIll builMsi dI:Ilftl' ic is leM by co.,wd;!]1y IKOpized IMIlliPIICf'ike. A PIIIy IIIq cbu:e iCJ
IIWra.1 ~ 'IIri&n aoIiu P..ctlIO ~ oW httj befctt ct.t ~daleor IIdI dIa!p.
' \6
CeroJ..oel$ sMlI be
~D
CiAOka btCWeu SOW 1M A&nc1i0llt, If til.., iI ~ict baiWl;tIIlbe tum. of thh Mutu L/ftse
tlletUIMtild oolllikloru illthld4 Wl'llltn o.lWIieWle sow, IbiJ ~1tcI ~ ~looMlsurJe
o:pIicilly uat&d. oj),~ il 1hc: IPpIUb" sow, lad iIId!Lt we 1M CIfIft)cdo, nDi ,"dOlIlfitiom ill well SOW apply 10
14.11
~elllCfllwt
IbISOWonly.
14.12 Il~J'inIDIiIkrs. tfwljllP~!IIo ~,orexllJeCticm_ tulUdioaartto:dy ror~cniemirA
IMII ~~t DO dT:t upon ~ 01iT:terpm:lioll ()fddJ Ap~.enL Thc Ma actr.owiqe 1II.1hi$ ApIMlll '111'
pt6pNtci by boI' hnlosJolMIf.
Itll aIitt AtreclltD.(, Willl/tSPt:l to the SenoIc. pr<Mded IIHkr dUI ~ Ibis ACOC/IIUI~ C()MU, ~ doo
h4ert1 ~~IIIM Ret\lllllol\ w.sriN1CII d.t ~ ~_ bcNc:JI !M Paniu .itA ~CJ til pritr 1M
c()1I~acretmer.u&r.d ~~ ofNPtI!ItJ, NOlllOdiftarilWlOthit~II(. dl'oc:Uw_ n.
wrilins -1Iifd by bGdI P3r1ic.
THI. tARTIES Jf",V RRA.1). UNDtJtSTOOD AND AGREED TO THE TUMS M'D (OriD-IT/ONS or mlS
ACJt.E:,'I1tN'l'.
IUR..\UOPTm; 'UWC tllIT, ON IUfAL1 or

COlELOG1C SOumOIiS, UC
nu: CONSUMU ,mANCB rROTtC'nON' BUREAU l"CORELOGlc-)
("CUSTOMtR'")
"!
'1:
, JA<.D]!;
03Gtl-U,.J
Tidc:u,,,,,'T'n-AG-TlI>Jl:r
it>
<fI-.FIl'{L
8("'/1'2...
Dale:
~=~Y~J~
tL,,-=--L -
,.., _-=fO+(.:... . .+-I""1'I..=-Ad~
Adilftss:
4fits!,u,ericaa Wq
$ala Au. ClNbJia m01
VerDate Nov 24 2008
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'''''''''00
lJ.11IkJ
358
STAH~IENT
Of WORK 1
This Slllltmenl ofWorl.: I esow Ii is b.!tween CoreLogic Solutions, LLC, a California limited liabilil)' Ctlmpany
("Core Logic"), and The Bureau of the Public Do!bt (~BPD), on behalf ohlle Consumer Finaoce ProteClion Bureau
("CFPB" and with BDP, "Customer"XCtlllectil'e!y,!he ~Panies," or irdil'idwHy, a "Party"). This SOW I is subject
10 !he allacred Master LiCl!M! Agreement of even date here\\;!h, and all subsequent amendmeltS, exlubits, or
attaclnnents ("Agreement") between the Parties This SOW I is effectil'e upon the date of last signature ("SOW I
Effective Date"). The Parties agree as follows
I.
CoreLogic shall provide OIstomer with the Services listed below via the
specified dtlil'ery method. Customer shall pay 10 CoreLogic the Fees set forth below. If the chart below
iooicates that an exhibit is anached, the additional terms aoo conditiOO'; set forth in the exhibit awly to the
Sc:rvice
SERVIC!:S, Il WVERY & r [ES:
Mlnn, FffS& Additional Information
Deliwtyvia Secure File Transfer Protorol \SFJlY)
A. LOA." U:V[I, i\JORTGAGE DATA
II. ADDITIONAL FIE & DELIVERY I,' ifORMATlON:
A. L~an J.A>nl Mortgagt [bla: The Loan Level Mortgage Data Services shall oonsisl of the data elements
shown on the attached Loan Level Mortgage Data Exhibit (Technical Requirements).
R. Feu: Customer shall pay CoreLogic the Fees set forth in the oonlr3ct.
IU. PER.\1tlTE1) '\pPUCATIOl>iS: Customer and Permitted Users ~ifled below shall use the Services solely for
the applicatiOO'; specifled below in accordance 1I;!h the terms and oonditions of !his Agrcement
A. euslomer's Ust:
In accordance with the terms of the Agreement, Customer may use !he Loon Level Mortgage Data for
Customer's internal bu;iness pmposes of risk malllgement and portfolio analysis. Customer may also
use the Loan Level Mortgage Data, alone or 1I;lh other information Customer creates or obtains from
other oota providers, 10 create analysis, reports, aoo research for both internal and external use
("Customer's Rep:xtsi. Customer may publish Cu;lomer's Reports on Customer's website, in
academic Journals, po~cy report<; and other media and may acknowledge CoreLogic as a SO\[CI! of
data used in Customer's Reports. Any such publications shall only ioclOOe immaterial portions of !he
Services, in aggregate form, and will include no loan Iml data
Customer srnll not attempt, directly or indirectly, to
disassemble the Loan Lml Mongage Data Services.
rev~
engineer, deaoonymize, decompile, or
CoreLogic shall retain all righ~ title aoo interest in and to ~ Loan LmJ Mortgage Data. Customer
slJill retain all right, title and interest in and 10 the Customer's Reports. Prm'ided Cllitomer has
complied with all terms of the Agreement and this Section lIlA, Section 7.3 (Return or Destruction
of Materials) of the Agreement shall not apply to the Loan Lel'el Mortgage Data Cmtomer has
iocorporated into the Customers Reports following termination or expiration of this SOW.
Except as expressly provided in this SectionIII.A, Customer shall not otoowise smliceme, resell, or
prm'ide the Loan Lel'el /l-btgage Data in whole or in part to any third party.
IV, Sow TtR.\1 A;\TI RJ\"[WAL: The term of this SOW I is for twelve (12) months, commencing on the SOW I
Effeclil'e Date. Thereafter, the term of this SOW may be renewed by Customer for four (4) additional tweln
(12) month terms
V. EXEUlT10)i': This SOW I may be executed in any number of CO\IJ.teIpar\s, esch of which is deemed an
original, aoo all taken together constirute one and the same instrument If this SOW I is executed in
counterparts, no signalory is bound Wltil all Parties have duly executed this SOW 1 and aU Partres have
VerDate Nov 24 2008
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Pagel of8
359
-_. --10. 6616 P.
-- AU!. 2. 201112: 5IPI
rc~ I fully e~6CIlteO sow I. Tho ~~ a.:I:nowlcdge tMIl1!j >.ipalur~ Inn$mill:d by facsjl'llil~ or 0!lUi1 (m .pdf, ,II' Jpo," ot I ttlll;11Ir fimIIaI). or~ PM!I\CCPy cfs.eh lRumislic .... i$ dc~cd 10 corwilttc me
ori~ sipatliro ottuch p!lt)' 10 !hi, SOW I. ~ Individual, Psnin& bollow ttjlfCSi:I'II dw Ibey ar; ~udIOriu:I
10 do SI) by MId 011 bebllf oflht PlIny t'ot whollllbc)' IR :Ii;nm"
o.
THE rAlTl!S HAVE RE ... UNDASI'OOD ANt) "GRElD '1'0 TIlE tUMS M'D CON'llm()NS OF
TH!SSOWI.
THE BUREAU orrnt lU8UC DEBT, ON

BElIALl1 (W11{E CONSUMR nNANCF:
COnLOGiC SOltmONS, LI..C
("COUI.OGIC")
VerDate Nov 24 2008
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PRoncrloN BUIEAU rcuSTOM~ft)
360
TECHN ICAL REQUIREME NTS

TPD-CFP-12-C-0010
TECHNICAL REQUIREMENTS
Appro~ate
res~nse,
support levels will be provided wHh respect to the data (i.e., SlA, JXliri.of contact, time for
etc.)
Datasets include loan-level data that allows CFPS to idertify relationships be\W"een loan featlJ'es and
defauH risk
Datasels combine origination data w~h Klan performaoce data
Datasets contain at leasl25 million active loans as of 12131f2011
Datasets are timet)' (Data will be provided less than 45 caleooaf days aller each month's end)
Datasets contain data integrity arK! support
Full rights to publish research, analyses. reports, and otherworl< based on these datasets are provided;
No advance nobce of advance review of, or permission for publicatioo is r.ecessary;

Right to reference use of the dataset in publications and other public commlXlications using the data is
fYOVided;
Right to publish research, analysis, reports, and other work sl.l\lives the license (i.e., CFPB has Itle right
to publish data ottained after the license has expired);
Righi to merge the data w~h all other datasets witl"oul affecting any CFPB usage or publication rights is
provided~ and
No use rest rictions are provided

If, and when, any newfields are added to the dataset the CFPB data dictionary will be up:::lated and a
clear exptanatiOO of charges/updates will be provided; aro
CFPB access to the web.t:esed p:)rtal is provided
CFPB has the ability to include custom fie lds in the datasets
Datasets will be made availatje in standard formats (e.g. csv, tat).del i m~ed text, XML) that are natively
compatible for Ioadirg into SAS SeNer, PostgreSOL, and MS SOL Server errvironments;
Datasets will be made availa~e in a user.friendly web interface;
Datasets will be made availatje to CFPB via OOrMlOfl fi le transfer protocols (e.g., SFTP); aro
VerDate Nov 24 2008
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If alAhentication is required for accessing the prodLd, CFPB will te provided required crederiials.
361
Experian

BUREAIJ OF THE I'UBUC DEBT
PARKERSBURG, VN 26106-1328
14 September 2012
Expenan Information SolutiOI'\$, Inc
1410 K Sl!et\ NW, Suite SO l
Washingt<:n, DC 20005
Subjett Callrael NlfllberTPD.cFP-1H:'OOI6
Coogratulatimsl Enc!Cd is the cauract a\\lIId ftT Corruner Credit Infamaticn Pane! in
.UPJmt ofme CorIsumef Financial PrOle.:ticn Bureau (CFPB)

Please lel'iew the endCd cermet award and if in agreement, please eanplete t:ioc~ 30a, JOb
and30c at Page I ofme Slalliard Fam 1449. B)'si~ the SFI449, yOllacknowledgeand
acoepI the lenns and conditions oflhis cootract. After si~ the document, please jKOIJide a
ropy of the signed fonn lia email 10 carev.grrop?bpd.treas.gcw.
Please nc(c thata Subcoonacting Waiver has been grued and therefore FAR 52.219-9 Alt Il
and FAR 52.219.16 hal'e been renJO\'ed from the Supplemer!lal Terms, Ccndtions and Claw;es.
After f1111IId, anyqu$ion> or isslltS relaled 10 !lis procurernenl will be hamted byrne Cattracl
AdrrriniSirabon Br.mch &1 mIUICti!dmim\lraticnl1bpcitrea<_@(IV. When sending an e-mail to this
adt.tess, please ioclllde the order Il.IIl1ber in the subjet\ line of the e-mail.
The follQll,ing are allhorized to place ordefs again>1 subject cootracI: Any I'.1II!alIIed Cortracting
Oflicu (CO) for the Bmrou of the POOlic Debt (BPD), Division of Procuremert, may place
ordefs again>1 this cm/I3ct. The cm/I3ct hclder sha!1lr)1 provide anyjl"oducts or seMces
"ithot rMI1ng an awarded ordeJ signed by the CO
Ms. Xiaoling Arg tos been designated Contracting Oflker's RepTesentatil'e (COR) for tIlis
COTIDld. Ms. Ylil Wen ling bas been designated Altemate COR fC( iii! cootract. A ropy of
QUI leners so designating Ms_ Arg and M
s_Ung are erdosed for}l:lll" infC(lll3.tion. They cordain
infocmatioo on their dulies and the scope of their aillhority in !lis ca!Dcity of ..ruch yOll shoold
be aware. Ms. Arg may be leached at 202-435- 7686 (If lia e-mail at xia<iing.ang1icfub.gO'l.
Ms. Ling may be leached al ZOZ-41'i-9251 or lia e-mail at l'llhwen.li ng'itcfOO gov.
VerDate Nov 24 2008
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Endos\l'es
362
r.e,1 1
1'' ' '-'SOiHlN .....rm
SOLiOTA nONICOHTRACTIOROER FOR COMNERCIAllnNS
1:-..d-~~
OI'F<ROR rOCOWUTILOCKS ll, 11, lJ, 24,' JO

,~~
TPD-CFP- 12- C- OOI6
SCOOTlllON
FOR10llC1TAOON
IN'ORJtO,TIOMCA"
~= OOTSON
1,S9.{OS'l
{;(U
IBPD-CGROPP
O~
0".
IIALl11NSTEmlS'l
IT"
]':1
"' ....noENT ...... ~.~S'I
EXPERIAN INFORMATION SOWTINS INC- l

475 ANTON BLVD
OOS1A MESA CA 92626-7036
..
C(fi
~PO
C(fi
~RCI ASol APB
Rc/ASO/APB
RC/ASD/APB, AVERY 3G
PO BOX 1328
CCOUNTSPAYABLE@BPD . TREAS . OOV
PARKERSBURG W 26106- 1328
~~
I'"
W"I CHEOCI' ISIrrr~ ISO'FSU/T _1'OT5'JO< .tUJ1ESS'" CfFEll
"
$7 , 00

Di vi.5ion of Procurement
drnini~tration Branch
very 5F
200 Thi rd Street
Parkersburg W 26101
r08642530
iU8illTtNC:ICESTO/olOeS_LNiI..OO<",lIIl.el1lil..OO< B8.~
,SCICI<ID
ocrEl.OI
" "
"
SQOO..ECfSiJ'f'<ffiSEJMoEi
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IIllWG
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,
IJFI.-Q
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Di'oISI,jCfRlIIll
{;(U
llZESTAIf:lOllO
rlo
T>lSC<.:mRO(1I$'
IIlJW<.:RWllfUR
Attn : Ms . Xiaoling ling

1700 G Street NIl'
Wa~hington OC 20552-0003
.-
!Wre561450
O~,
-~
COCE ICFPB
" . CCJITI'O.CTORI
-,--"""""'"
0_
/30 PROHPT PAY
DElMRTO
,~
D(VIOOO)a.ol(U_m::I'OI~
DIUIlONEs,,",u
O~~
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I'OIEH-CMIIWSIOIU~
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~"'.ES$(I.00<1S
Off8!rueo.ThlOCl<l.IlIE
II:! Vlf6J1l1.;-JWOR
,I TNSo.coo:sollON1S
07/03/2012
""'_'""I r ET
I'~-
Bure"u of Public Debt

Divi~ion of Procurement
Avery 5F
200 Third Street
Attn : C. Gr0rP
Puker~burg WV 261 01
f,i"~
jiBPD-CFP- 12..... CI - 0004
09/24/201
l'
8EIl
~"
"
-~
.~
he purpcn!e of thi.s firm- filled- price (FFPI

Indefinite Delivery/Indefinite Quantity (I0IQ)
ward i~ to provid a ConSUI'Llr Credit Information
aMl in support of the ConsUI'Ll",r Financial
rQtection Bureau (eFPB) in accordance wi th the
ttached Statement of Work (SOW) .
he Contractor ~h~ll provide ~",rvices only as
uthorized by task order , and in accordance with
the IDIQ contract .
W~
RMM , 1l!Vor AlIKh Addlm,'SMels IS /leceSSlry)
15 ACCO\.III"'GMON'PROPII"T(lNOATA
10I.o.tA.....slO .... OUNT 11_ l!ao"",
Se schedule
$0.00
011. SOlCIIAT(lN NCORPOAAIESBYREfERENct FAAl1111-1, ~l'l~ F.o.RIlll2-3 MO~ 111lAReATTACHEO
1iil 11b
CONIR.'':;UUU;MASE OIlOER NCOI>PORATES 8'Y
REFE~Nct FAA 1111~ FAA ill1lllSATTACHEO
~18 COlfrR.I<:TOR lSREOO RfOTOSGNHIISOOQJIoIENI NlDRfTUlIN

COP ES 10 ISSU NG OFF(E CONTR.I<:TOR AGREES 10 FUIINISHMC:> DE,N'ER
AU rTMS SET FORT~OR omER~s OENTfEOI-OOVE NlO ON IWY 1OO!T1ON.>l
SH:OISSU8.lOCI TO THE TER~ANOC(lNorrI,)NS ~ECI'IfO
AOOENO
1OOEN()o'
DME
DAAENOUTIACHEO
GlARe
DARe NOT ATI.o.cMEO
o 19 AWAAIl OF CONTRACT
OFFER
OAIEO
YOUR OFFER ON SOLClTAII(lN 1f!.00< It
rlQ!llfi(;.oIIY .ooo~IONSOR ClWlGES VlHCH AAE SEI fORTH
HEREIN. IS .l<:CEPlEOAS 10 rTtlolS
j3O<0ATES~EO
ISA R. STANLEY
I-IJIHORllEDfOR lOc.o.t RH'ROOUCllON
VerDate Nov 24 2008
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IT.oJIOARDFORM ImIRE'I. 11I011)

I'n Kribod bycso. F/Jt (E CfR)63212
PRO\fIO\JSED'H',lN ISNOTUsoaE
363
2 of
18
- Di r ector ,
IGo",~'m' POe/COR ; Ms . Xiaoling ling

202 - 435 - 7666
xiaoling . ang@cfpb . gov
IGo",,~'m' Alternate PCC/COR ; Ms . Yuh \Olen Ling

202 - 435 - 925 1
yuhwen . ling@cf[:b . gov

Condition~
and
Clau~e~
lnvoice~
are a ttached hereto
are to be
on a task order basis .
~ubmitted
Invoices wi ll be
will be handled by the Cont ract
I""iei"'''ioo Branch at
loo"",,,,,,,,ioi,,,,,,i,o",,, .treal! . gov .
When
an e- mail to this address , please i nclude

the
31. QUNIIITY .. COll.!ON
o
J1b
SIGH~TURI'
11 HAS BEEN
o INSPEcn:o
RECEIVEO
ta~k
o ACCEPiEQ 1<NO CONFORMS 10 TIE CONIRACT. EXCEPT ASHOTED

1310 DAlE
Of .o.JJIHORI/EOGOI'5lNMENI REPRESENTATM;
.12. IoIAI. NG p.f()IlESS OF AiJlHORilID GOVERNMENT REPfIE5ENTAlI'IE
31< PIlNIUl NAME.o:IO mtE Of AlJIHORllUl GOVERNMENT
RE_SEm~TIVE
III TELEPHONE II.It.ftR ~ AlJTHORllUl GOVERliMENT REPRESENT~TIVE
Jig E-MAl Of .o.JJIHOR[EQ GOVER'iMENT REPfIESENT~I"' E
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." 1CEI!TfY THIS,o,cCQUIT IS COR'lECT AJI;) PROPEl! FOR PAVMENT
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41.
364
CEI'O~l'OCI./I08ITEII3!(;COI<TIN1!8l
CONTINUATION SHEET PD-CFP- 12-C- 0016
!8
IWOEOFOFFffilRORCCI<TI!.cTa!
EXPERIAN INFORI1ATION SOWTINS INC- l
-~
Ic)
18 1
IAI
h~ ov~rall
lIIinimlllll for thi5 con t ract i5 :

1, 622 , 800 . 00
h~ minimUIII i5 guarant~ed
he overdl maximum for this contract is :
8, 426, 650 . 00
he minimum aI:lount for an order against this
ontract is : $6, 000 . 00
he maximum aI:lount for an order against this
ontract is : $8, 426, 650 . 00
Period of P~rformanc~ : 09/ 24 / 2012 to 09/ 23/ 20 17
0001
Base Period - CFPB CoIll'lUI:ler Credit Information

Panel
ID
_ 0
.~
lEi
IF)
5, 287, 050 . 00
Refer to Attachment I - IDIQ Pri ce Schedule

Award Type : Indefinite- quantity
Min . Qty : N/ AI Max . Quantity : N/ A
Mi n. Amt :
$1 , 622, 800 . 00 1 Max . Amount :
5, 287, 050 . 00
Minimum Guaranteed : Y
Penoo of P~rformanc~ : 09/ 24 / 2012 to 09/ 23( 2013
000 2
0 . 00
~~ion
Perioo I - eFPB Con."lumer Credit

Information Pan~ l
Refer to Attachment I - IDIQ Price Schedule

J\<Iard Type : Ind~finite- quantity
Min . Qty : N/AI Max . Quantity: N/ A
Min . Amt :
50 . 00 1 Max . Amount :
784 , 900 . 00
Minimum Guaranteed : N
Amount : $784 , 900 . 00 IOption Line It~IlI )
Perio::1 of Performance : 09/ 24/2013 to 09/23/ 2014
0003
Op~ion P~riod
2 - eFPB
Information Panel
Refer to
Attachm~nt
Con5um~r
Credi t
0 . 00
I - IDIQ Price Schedule
J\<Iard Type : Indefinite- quantity

Min . Qty : N( AI Hax . Quantity: N/ A
Mi n. Amt :
SO . OOI Max . Amount :
784 , 900 . 00
Amount : $784 , 900 . 00 IOption Line Item )
Continued ...
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365
CEHO <:1'CIlO.OIEIIl88"'C(JNIIjIJ8)
CONTINUATION SHEET PD-CFP- 12-C- 0016
18
_OI'OI'fCllORORCOITR4C1OR
EXPERIAN INFORMATION SOWTINS INC- l
,e,
-~
1"
lA'
Periocl of Performance : 09/24/2014 to 09/23/2015

0004
[0
_"0
''I
.~
1"
~~ion
P,.riod 3 - CFPB Consumer Credi t

Information Panel
0 . 00

Award Typ,. : Ind,.finite- quantity
Min . Qty : N/lIl Max . Quantity: N/ll
Min . Amt :
SO.OOI Mall . A!lIount :
784 , 900.00
Amount : $784 , 900 . 00 IOption Line Item )
p,.riod of h>rfonnanc,. : 09/24/2015 to 09/23/2016
0005
Option Period 4 - CFPB Consumer Crem t

Information Pand
0 .00

Award Type : Indefinite- quantity
Min . Qty : N/A) Max . Quantity : N/ll
Min . Amt :
SO.OOI Mall . Amount :
784 , 900 . 00
Amount : $784 , 900.00IOption Line Item)
Penod of Perform~nce : 09/24/2016 to 09/23/2017
h,. total amount of award : S8, 426, 650 . 00 . The
obligation for this award is ~het.m i n boll 26 .
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366
TERMS, CONDITIONS AND CLAUSES
SOFTWARE FEDERAL DESKTOP CORE CONFIGURATION (FDCC)

AI software wtll::h is designed to run on Windows Vista or XP desktops must function without modification to the
Federal Desktop Core Configuration (FDCC) security configurations developed by the National Institute of Standards
arod Technology (NIST), the Department of Defense (DoD) and the Department of Homeland Security (DHS).
Software and hardware products that are deSigned to operate in environments other than the FDCC desktop must
have a standard configuration guide published on the NIST website, or the vendor must supply a recommended
configuration guide for all configurable security settings.

The corrtrutor agrees to submit, within ten business (10) days from the date the contract is awarded (exclusrve of
Saturdays. Sundays. and federal holidays). a textbased .p:!ffile of the fully executed contract or task orderw~h all
proposed necessary redactions, including redactons of any trade secrets or any commercial or financial infonnation
that ~ believes to be privileged or confidential business information, for the PJrpose of public disclosure at the sole
discretion of the Consumer Financial Protection Bureau (CFPB). The contractor agrees to provide a detailed written
statement specifying the basis for each of its proposed redactions, including the applicable exemiXion under tile
Freedom of Infonnation Act (FOIA), 5 U.S.C. 552, and, in the case of FOIA ExemiXklO 4, 5 U.S.C. 552(b)(4), shall
demonstrate 'Nhy the info nnation is considered to be a trade secret or commercial or financial infonnation that is
privileged or confidential lnfonnation provided by the contractor in response to this contract requiremenl may itself be
subject to disclosure under the FOIA. The CFPB Ylill carefully consider all of the contractor's proposed redactions and
associated grounds for nondisclosure priorto making a fi nal delermination as 10 wIlat information in the fu l ~ executed
contract may be propeny withheld. In the event that the CFPB disagrees with the corrtractor's suggested redactions,
the CFPB will provide the contractor with notice prior to posting the contract
PRODUCT PROVISIONS
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52.212-4
CONTRACT TERMS AND CONDITIONS - COMMERCIAL ITEMS (FEB 2012)
(a) Inspection/Acceptance The Contractor sha~ only tender lor acceptance those nems that conform to the
requirements olthis contract. The Government reserves the right to inspect or test any supplies or seNices
that have been tendered for acceptance. The Government may require repair or replacement 01
nonconforming supplies or reperformance of nonconforming sel\'ices at no increase in contract price. II
repa ir/replacement or reperformance 'Nill not correct the defects or is not possible, the Government may
seek an eq u ~able pice reduction or adequate consideration for accejXance 01 nonconforming supplies or
seMces. The Government must exercise its post-acceptance rights(1) Within a reasonable time after the delect was discovered orshould have been discovered; and
(2) Before any substantial change occurs in the cond~i<m of the item, unless the change is due to the
defect in the item
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(b) ASSignment. The Contractor or its assignee may assign its rights to receive payment due as a resuH of
performance of this cootractto a bank, trust company, or other financing institution, including any Federal lending
agency in accordance with the Assignmentof Claims Act (31 U.S,C. 3727). rio'M!ver, wtlen a third party makes
payment (e.9., use of the Governmentwide commercial purchase card), lIle Contractor may not assign its r;ghts to
receive payment under this contract
(e) Changes . Changes in the terms and conditions of this contract may be made only by written agreement of
lIle parties.
(d) Oispu/es. This contract is subject to lIle Contract Disputes Act of 1978, as amended (41 U,S.C, 60t-613).
Failure of the parties to this contract to reach agreement on any request for equitable adjustment, claim, appeal or
action arising under or relating to lIlis contract stlall be a dispute to be resolved in accordance with the ctause at FAR
52.2331, Disputes, wtlich is incorporated herein by reference. The Contractor shal proceed diligently with
performance of this contract. pending final resolubon of any dispute arising underthe contract.
(e) Definitions. The clause at FAR 52.2021, Defin~io n s, is incorporated herein by reference
(n Excusable delays. The ContractorshaU be liable for delauH unless nonpelformance is caused by an
occurrence beyond the reasonable control of the Contractor and without its fauH or negligence stich as, acts 01 God or
quarantine restrictions, strikes, unusually severe weath er, and delays of common carriers. Th e Contractorshall notify
lIle Contracting Officer in writing as soon as ~ is reasonably possible after the commencement of any excusable
delay, setting forlt1 the lull particulars in connection therewith, shall remedy such occurrence with all reasonable
dispatch, and shall prom~ly give written notice to the Contracting Officer of the cessation of such occurrence
(g) Invoice. The Contractor shall submn an original invoice and three copies (or electronic invoice, ~ authorized,)
to the address designated in the contract to receive invoices. At! invoice must include-(i) Name and address of the Contractor,
(ii) InV{lice date and number,
(iii) Contract number, contract line item number and, if applicable, the order number,
(iv) Description, quanbty, u n ~ of measure, unn poce and extended pice of lIle nems delivered;
(v) Shipping number and date of shipment, including the bill of lading number and weight of shipment ~ shipped
(vi) Terms of any discount for t:rom~ payment offered;
(vii) Name and address of official to whom payment is to be sent;
(viii) Name, title, and pllone number of person to be notified in event of defective invoice; and
(ix) Taxpayer Ident~ication Number (TIN). The Contractor stlall include its TIN only rt required elsewtlere in this
contract.
(x) Electronic lunds transfer (EFn banki ng information
(A) The Contractor shal incll.'de EFT banking informabon only I required else'lYhere in this contract
(B) If EFT banking information is not required to be 00 the inV{lice, in order lor the invoice to be a proper
invoice, the Contractor shall have submitted co rrect EFT banking information in accordance with the applicable
solicitation p-oviskln, contract clal/Se (e.g" 52.232-33, Payment by Electronic Funds Transfer--Central Contractor
Registration, or52. 232-34, Payment by Electronic Funds Transfer-Ot her than Central Contractor Registration), or
applicable agency procedures.
(C) EFT banking information is not required if the Government waived the requirement to pay by EFT
(2) Invoices will be handled in accordance with the Prompt Payment Act (31 U.S.C. 3903) and Office of
Management and Budget (OMB) prompt payment regulations at 5 CFR 1315.
(h) Patent indemnify. The Contractorshall indemnify the Govemment and its officers, employees and agents
against liability, including costs, for actual or alleged direct or contributory infringeme nt of, or inducelllnt to infri nge,
any United States or foreign patent, trademark or copyrig h~ arising out of the performance of this contract. provided
the Contractor is reasonably Mbfied of such claims and proceedings.
(i) Payment. (t) l/ems arxepled. Payment shall be made for items accepted by the Govemment that have been
delivered to the delivery destinaUons setforlt1 in lIlis contract.
(2) Promptpayment. The Government wi ll make payment in accordance with the Prompt Payment Act (31
USC. 3903) and Office of Management and Budget (OMB) prompt pay regu lations at 5 CFR 1315
(3) Electronic Funds Transfer (EFT). If the Govemment makes payment by EFT, see 52,212-5(b) for the
appropriate EFT clause
(4) Discount. In connection with any discount offered for early payment, time shall be computed from the date of
the invoice. For the purpose of computing the discount eamed, payment shall be considered to have been made on
the date wtlich appears on the payment check or the specified payment date rt an electronic funds transler payment is
made.
(5) Overpayments. lIthe Contractor becomes aware of a duplicate contract fi nancing or inV{lice payment or that
the Government has otherwise overpaid on a contra ct financi ng or invoice payment, the Contractor shall(i) Remit the overpayment amount to the payment office cited in the contract along with a description of the
overpayment including thePage (7
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(A) Circumstances of the overpayment (e.g. , duplicate payment, erroneous payment liquidation errors,
date(s) of overpayment);
(8) Affected contract number aoo deMry order number, if appicable;
(C) Affected contract line aem or subtine nem , d applica~e; and
(0) Contractor po4nt of contact
(ii) Provide a copy of the remittance and supporting documentation to the Contracting Officer
(6) Interest.
(i) All amounts that become payable by the Cootractor to the Government under this contract shall bear
simple ilterestfrom the date due until paid unless paid wi1Ilin 30 days of becoming due. The interest rate shall be the
interest rate established by the Secretary of the Treasury as provided in Section 611 of the Contract Oisputes Act of
1978 (Public law 95.-563), ...mich fs applicable to the period il which the amount becomes due, as provided il (i)(6)(v)
of this clause, aoo then at the rate applicable fo r each sixmonth period as fixed by the Secretary until the amount is
paid
(ii) The Government may issue a dt!mand for payment to the Cootractor upon fi nding a dett is due under the
contract
(iii) Finaldecisions. The Contracting Officerwill issue a final decision as required by 33.211 if(A) The Contracting Officer and the Contractor are unable to reach agreement on the exisler.ce or amount
of a debt within 30 days;
(8) The Contractor fa il; to liquidate a debt previo usly demanded by the Contracting Officer wi1Ilin the
tmeine specified il the demand for payment unless the amounts were not repaid because the Contractor has
req uested an installment payment agreement or
(C) The Contractor requests a deferment or collecton on a debt previously demanded by the Cootractilg
Officer (see 32.607-21
(iv) If a demaoo for payment was previously issued for the debt. the demand for payment included in the final
decision shal identify the same due date as the original demand fO( payment
(v) Amounts shall be due at the earliestol the following dates
(8) The date of the first written demand for payment inciooing any demand for payment resulting from a
de/auH termination
(vi) The interest charge shall be computed for the actual number 01 calendar days involved beginning on the
due date and ending on-(A) The date on which the designated office receives payment from the Contractor;
(8) The date of issuance 01 a Govemment check to the Contractor from which an amount otherwise
payable has been withheld as a credit against the contract det:t; or
(C) The dale on which an amount withheld and applied to the cootract debt would otherwise have become
(vii) The interest charge made under this clause may be reduced under the procedures prescribed in 32.608~ of the Federal Acquisnion Regulatioo in effect on the date of this contract
U) Risko/loss. Unless the contract specifically provides otherwise, risk 01 loss or damage to the supplies
provided under this contract shall remain with the Contractor until. and shall pass to the Government upon
(1) Delivery of the supplies to a carrier, ~ transportation is I.o.b. origin; or
(2) Delivery of the supplies to the Government at the destination specified in the contract ~ transportabon is
I.o.b. destination.
(k) Taxes . The contract price includes all applica~e Federal, State, and local taxes and duties
(I) TerminatiJn for the Government's convenience. The Government reserves the right to terminate this contract,
or any pari hereof, for its sole convenience. In the event of such termination, the Contractorshall immediately stop all
work hereunder and shal ilMlediately cause any and all of its suppiers and sub:::ontractors to cease work. Subject to
the terms of this contract, the Contractor shall be paid a percentage of the contract price reflecting the percentage of
the work performed prior to the notice of terml1ation, pkJs reasonable charges the Conlractorcan demonstrate to the
satisfaction of the Government using its standard recom keeping system, have resu~ed from the termination. The
Contractor shall not be required to comply with the cost accounting standards or contract cost principles for this
purpose. This paragraph does not give the Government any right to aud~ the Contractors records. The Contractor
shaD nol be paid for any work performed or costs incurred ...mich reasonably couk! have been avoided
(m) TerminatiJn forcause. The Government may terminate th is cootract, or any part hereof, for cause in the
event or any defau~ by the Contractor, or ~ the Contractorfais to comply wi1Il any contract terms and conditions, or
fails to provide the Government upon req uest wi1Il adequate assurances of future performance. In the event of
termination for cause, the Government shall not be liable to the Contractorfor any amount for supplies or services not
accepted, and the Contractor shal be liable to the Government for any and all rights and remedtes provided by law. If
nis dele/mined that the Government improperly terminated this contract for default. such termination shall be deemed
a termination for convenience
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(n) Tille. Unless specified elsel'rflere in this contract title to items furnished under this contract shaD pass to the
Government upon acceptance, regardless of when orwhere the Government takes p,ysical possession
(0) wananty. The Contractorwarrants and impijes that the ~ems delivered hereunder are merchantable and fit
for use forthe particular purpose described in this contract
(p) Limitation of liability. Except as otherwise provided by an express warranty, the Contractorwill not be liable
to the Government fo r consequential damages resuHing from any defect or deficiencies in accepted ~ems
(q) Other compliances, The Contractor shall comply with aU appticable Federal, State and local lav.s, executive
orders, rules and regulations appmcable to its performance under this contract
(r) Compliance with Jaws unique 10 Govemmenlcontracls. The Contractor agrees to comply with 31 U.SC. 1352
relatin g to limitations on the use of appropriated funds to ilfluence certa" Federal contracts; ~ relating to
officials not to benel~: 40 US C 3701 el seq, Contract Work Hours and Safety Standards Act: 41 USC. 5158 Anti
Kickback Act of 1986; 41 U,S.C, 265 and 10 U,S.C 2409 relatng to whislleblawer protections; 49 U.S,C. 40118, Fly
American; and 41 U.S~g to procurement integnty
(s) CXderof precedence, Any inconsistencies in this solicMon or contract shall be resolved by !Ping
precedence in the follOl'.in g order
(1) The schedule of supplies/services.
(2) The Assignments, Disputes, Payments, Invoice, Other Compliances, and Compliance with Lav.s
Unique to Government Contracts parag raphs of this Clause
(3) The clause at 52,2125
(4) Addenda to this solicitation or contrac~ including any license agreements for computer software.
(5) Solicitation provisions if this is a solicitation
(6) Other paragraphs of this clause
(7) The Standard Foon 1449
(9) The specrtication
(t) Central Conlractor Registratioo (CCR).
(1) Unless exempted by an addendum to this contract, the Contractor is responsi~e during performance and
through fi nal payment of any contract forthe accuracy and completeness of the data within the CCR database, and for
any liability resutting from the Govemment's reliance on inaccurate or .,complete data, To remain registered in the
CCR database after the innial registration, the Contractor is required to review and update 011 an annual basis from
the date of initial registration or subsequent up:lates its informatKln in the CCR database to ensure n is current
accurate and complete. Up:lating information in the CCR does notalter the terms and conditions of this contract and
is not a su bst~utefor a propeny executed contractual document.
(2)(i) If a Contractor has legally changed its btlSiness name, ' doing 'oosiness as" name, or division name
(I'rflichever is shown on the contract), or hastransferred the assets used il performing the contract, but has not
completed the necessary req uirements regarding novation and cha nge~name agreements in FAR Subpart 42. t2,
the Contractor shall provide Ille respJnsible Contracting Officer a minimum of one business day's written notWication
of its intention to (A) charoge the name in the CCR database; (6) comply with the requirements of Subpart 42, 12; and
(C) agree il writing to the timeline and procedures specified by the responsible Contractng Officer. The Contractor
must provide with the not~ication sufficient documentation to support the legally changed name.
(ii) If the Contractorfails to comply with the requirements of paragraph (t)(2Ki) of this clause, or fails to
perform the agreement at paragraph (t)(2)@C)ofthisdause, and, il lhe absence of a propel1y executed novation or
change<lfname agreement the CCR information that shews the Contractor to be other than the Contractor indicated
in the contract will be considered to be inconect information within the meaning 01 the "Suspension of Paymenr
paragraph of the electronic fu nds transfer (EFT) clause of this contract
(3) The Contractor shall not cIlange the name or address for EFT payments or manual payments, as
appropriate, in the CCR record to reflect an assignee for the purpose of assignment of claims (see Subpart 32.8,
Assignment of Claims). Assignees shal be separately registered in the CCR database.l nformabon provided to the
Contractor's CCR record that indicates payments, including those made by EFT, to an ultimate recipent other than
that Contractor wi ll be considered to be incorrect information within the meaning of the ' Suspension of paymenr
paragra ph of the EFTctause oflhis contract
(4) Offerors and Contractors may obtain information on registration and annual confirmation requirements via
CCR accessed through http.s'/ilvwlv.acquisiticngovor by cal~ng 1--888--2272423 or 269961 5757
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ADDENDUM TO 52,2124, CONTRACT TERMS AND CONDITIONS - COMMERCIAL ITEMS (FEB 2012)

Internet Payment Platform OPP) is a secure web-based electronic invoicing and payment information service available
to all Federal agencies and the ir supplier by the U,S. Treasur(s Financial Management Service. IPP allows Federal
agencies and theirsuppliers to exchange electronic purchase orders, blanket POS, in~ces, and payment nformation
in one easy to access web portal. This service is free of charge to government agencies and their suppliers, including
services and support
The preferred method fOI invoicing is IIlrough IPP. The IPP webs~e address is httos:llwMY,ipp,gov, Contractor
assistance 'Nith enrollment can be obtained by contacting the Bureau of the Public Debfs IPP Team at 3044808000,
OpUon 7 or IPP Production Help desk via email ipooroup@bosJrb,orgorphone(866)973-3131 .
If the Contractor is unable to utilize IPP for submitting payment requests, invoices may be submitted electronically to
lIle email address shown in Bbck 18a, page 1 after completing the IPP Wa'Ner Form and subrrltting ~ via emal 10
contractadministration@bcd.treasgov (see IPP Wa'r>ter Attachment) Adobe Acrobat Portable Document Format
(PDF) and Microsoft Word are acceptable formats. Invoices shall contain the information required in FAR 52,212
4(9).
Under this contract, the folo'Ning documents are requ ired to be submitted as an attachment to the invoice
None applicable
PAYMENT AND INVOICE QUESTtONS

For payment and nvoice questons, go to httos/1wMY ioo90\l or contact the Accountng Services Division at (304)
480-8000 opti:m 7 or via ema~ at AccountsPayable@bpd,treas,gov
OVERPAYMENTS
In accordance with 52.2124 secbon (i) 5 Oierpayments Accounts Receivable Conversion 0( Check Payments to
EFT: If the Contractor sends the Government a check to remedy dupicate contract financi ng or an overpayment by
the governmen~ ~ v.ill be converted into an eiectronic funds transfer (EFT). This means the Government will copy the
check and use the account nformation on ~ to eiectronically deM the Contractors account for the amount of the
check. The deMfrom the Contractor's account wil usually occur within 24 hours and wi ll be shown on the regula r
account statement.
The Contractorwill not receive the original check back. The Govemment shall destroy the Contracto(s original check,
but wi ll keep a copy of it If the EFT cannot be processed for technical reasons, the Contractor authorizes the
Governmentto process the copy in place of the original check
The Contractor shall ensure the contract number and taskldel'Nery order number is clearly visible on all
shippin!)'service documents, cootainers, and invoices
1052.20170
CONTRACTING OFFICER'S REPRESENTATIVE (COR) APPOINTMENT AND AUTHORITY (JUN

2012)
(a) The COR and the AHerna te COR are iden@edintheSF 1449, block 20.
(b) Performance of mr\( under th is contract is subject to the technical direction o(the COR dentified a'oove,
or a representat'Ne designated in writing. The term 'technical direction ' includes, without limitation, direction to the
contractor that directs or redirects the labor effort, shins the mr\( between mr\( areas 0( Iocatons, and'or fins in
details and otherwise serves to ensure that tasks oultined in the wor\( statement are accompished satisfactorily
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(c) Technical direction must be within the scope of the contract spec~ication(s}AYorio:: statement. The COR
does not have authority to issue technical direction that
(1) Constitutes a change of assignment or add~ional worio:: outside the contract specification(s)/w::lrio::
statement;
(2) Constftutes a change as defined in the clause enMed ' Charoges';
(3) In any manner causes an increase or decrease in the contract price, or the time ~qui~d for contract
performance;
(4) Changes any of the terms, coooitions, or speciflCation(s)/w::l1io:: statement of the contract;
(5) Interferes with the contracto(s right to perform under the terms and corlditions of the contrac~ or
(6) Directs, supervises or otheroYise controls the actions of the contractor's employees
(d) Technical direction may be omlor in writing. The COR must confirm oral direction in writing within five
wo rkdays, with a copy to the Contracting Officer
(e) The Contractor sha. proceed promptly with performance resuHing from the tecllnical direction issued by
the COR. II, in the opinion of the contractor, any direction olthe COR or the designated representative laUs within the
limitations of (c) aoove, the contractor shall immediately not~yth e Contracting Officer no later than the beginning 01
the next Govemment work day
(I) Failu~ 01 the Contractor and the Contractirog Officerto agree that technical direction is within the scope 01
the contract shall be subjectto the terms of the clause entitled Oisputes.'
1052,21070
CONTRACTOR PUBLICITY (AUG 2011)
The Contractor, or any entfty or representative acting on behalf of the Contractor, shall not refer to the equipment or
services furn ished pursuant to the provisions of this contract in any news release or commertial advertising, or in
connection with any news release or commercial advertising, without first ottaining eJCpIicit written consent to do so
lrom the Contracting Officer. Should any reference to such equipment or services appear in any news release or
commercial advertising issued by or on behd of the Contractorwithout the requ i ~d consent, the Government shall
consider institut()n of all remedies available under applicable taw, including 3t U,S,C. 333, and this cootract, Further,
any violation of this provision may be considered during the evaluaton of past performance in future competitively
negotiated acquisitions.
52.21618
ORDERING (OCT 1995)
(a) My supplies and services to be lumished under this contract shall be ordered by issuance 01 delivery
orders or task orders by the individuals or activities designated in the ScIledule. Such orders may be issued fro mthe
IClIO contract date of award through a date to be identl ied at time of award
(b) All delr.tery orders and task orders are subject to the terms and conditions of this contract. In the event 01
conflict between a delivery order or task order and this contract the contract shall control
(c) II mailed, a delivery order or task order is considered 'issued' wnen the Government dep:Jsits the order in
the mail, Orders may be issued ora ny, by facsimile, or by electronic commerce methods only I authorized in the
Schedule
52.21619
ORDER LIMITATIONS (OCT 1995)
(a) Minimum arJer. When the Govemment requirtls supplies or services covered by this contract in an
amount of less than $6000.00, the Government is not o~igated to purthase, nor is the Contractoro~;gated to furnish,
those supplies or services under the contract
(b) Maximum order. The Contractor is not obligated to honor(1) Any order for a single rtem in excess 0ISB,426,650.00;
(2) Any order for a combination 01 ~ems in excess of 58,426,650.00; or
(3) A series of orders Irom the same ordering office within 15 bllSiness days that together call lor quanUbes
exceeding the imitaton in paragraph (b)(I) or (2) of this section.
(c) If this is a requ irements contract (i.e., includes the Requirements clause at subsection 52,2162t oftfle
Federal Acquisition Regulation (FAR)), the Government is not required to order a part 01 anyone requirement from the
Contractor ~ that requirement exceeds the maximum-<lrder limitations in paragraph (b) of this section.
(d) Notwithstanding paragraphs (b) and (c) of this section, the Contractor shall honor any order exceeding the
maximum order limitations in paragraph (b), unless that order (or orders) is rtltumed to the ordering office within three
(3) business days aner issuance, with written notice stating the Contractor's intent oot to shipthe item (or rtems) called
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for and the reasons. Upon receiving this notice, the Gcwemment may acquire 1I1e supplies or services from another
source
52.216-22
INDEFINITE QUANTITY (OCT 19951
(a) This is an indefin~e-<luan~ty contractfor1l1e supplies or services specified, and effec\M! fo rthe period
staled, in the Schedule. The qua n t~ies of supplies and services specified in the Schedule are estmates only and are
nol purchased by Ihis contract
(b) Delivry or performance shal be made only as authorized by orders issued in accordance IVith the
Ordering clause. The Contractor shall furnish to the Government, when and if ordered, 1I1e supplies or services
specified in the Schedule up to and includiog the quantity designated in1I1e Schedule as the "maximum." The
Government sllall order at least the quantity of supplies or services designated in the Schedule as the "minimum'
(c) Except for any limitations on quanbties in the Order Limitations clause or in the Schedule, there is no lim~
on the number of orders 1I1at may be issued. The Govemment may issue orders requiring delivry 10 multipl
destinations or performance at multiple locations.
(d) Any order issued during the effectiv period of this contract and not completed within that period shall be
completed by the Contraclorwithin the time specified in the order. The contract shall gcwem the Contractor's and
Government's rights and obligations with respect to that order 10 the same extent as 11l1e order were completed
during the contract's effective period; {X"Ovided, that the Contractor shall nol be req uired 10 make any delivries under
this contract after the 12-month base period and four (4) 12-month option periods.
52.217-8
The Government may require continl!ed performance of any services within the li:nits and atlhe rates spec~ied in the
contract These rates may be adjusted only as a resuHof re'lisions to prevailing labor rales provided by the Secretary
of Labat'. The op:i:ln pro'lision may be exercised more than once, but the Iotal extension of performance hereunder
shall nol exceed 6 months. The Contracting Officer may exercise the op:ion by written notice 10 the Conlractor IVithin
30 calendar days before 1I1e contract expiration dale
52.217-9
OPTION TO EXTEND THE TERM Of THE CONTRACT (MAR 2()OO)
(a) The Government may extend the lerm of thiscontrac\ by written notice to the Contractorwithin the final
30 calendar days of each contract period; provided 1I1at the Gcwernrnent gives the Contractor a preliminary written
notice of its intenllo extend at least 30 calendar days before Ihe contract expires_ The preliminary notice does not
comm~ the Gcwernment to an extension.
(b) If the Gcwernmentexercises this option, the extencled contract shall be considered 10 inclucle this option
clause
(c) The total duration of this contract, including the exercise of any op:i:lns uncler this clause, shall not
exceed fiv (5) years.
CONTRACT TERM
The period of performance is a 12rronth base period and four (4) 12rronth op:ion periods
CONTRACT MINIMUM AND MAXIMUM

(a) The minimum amount the Government is obligated to order during the term of tile contract is $1,622,800.00
(b) The maxirrum amount of Ihe contract is 58,426,550.00.
PAST PERfORMANCE EVALUATION

This contract is subject to a performance evaluation 'lia The Contractor Performance Reporting System (CPARS) at
WMY_cpars.csd.disa.mil. Following the end of each contract period and al contract completion, a completed
Government evaluation shall be folWarded to 1I1e Contractor. The Contractor may subm~ written comments, if any,
within the time period specified in 1I1e evaluation transmitta l. The Contractors comments shall be considered in the
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issuance of the final evaluation document Any disagreement between the parties rega rding the evaluation shall be
forwarded 10 Ihe Bureau Chief Procurement Officer (SCPO) The final evaluation of the Conlractor's peliormance is
the deciskln of the SCPO. A copy of the final pelionnance evaluabon report wil be sent to the Contractor and 10 tI1e
Govemment"s past peliormance database atVNNIppirs.gov
52.212-5

EXECUTIVE ORDERS - COMMERCLAL ITEMS (APR 2012)
(a) The Contractor shall comply m;h tI1e folkJ,ving Federal Acquisition Regulalkm (FAR) clauses, ....tlich are
incorporated in this contract by reference, to implemenl provisions of law or Executrve orders applicable 10
acquis~ion s of commercial ~ems
(1) 52.222-50, Combating Trafficktl g in Persons (Feb 20(9) m U.S.C. 7104f9l)
_ AlterMte I (Aug 2(07) of 52.222-50 (22 U.S C. 71041ql).
(2) 52.233-3 Protest After Award (AuG 1996) (31 U.S.C. 3553),
(3) 52.233-4 Applicable Lawfor Breach of Contract Claim (OcT 2004) (Pub L. 108-77. 108-78)
(b) The Contractor shall colTJjlly with tI1e FAR clauses in this paragraph (b) that the Contracti ng Officer has
indicated as being incorporated in this contract by reference to implement provisions of law or Executive orders
applicable to acquisitions of commercial ~ems:
]_ (1) 52.203-6, Restrictions on Sulx:ontractor Sales to tI1e Government (Sept 2(06), with Alternate I
(Oct 1995) (41 U.S.C 2530 and 10 US.C 24021.
_ (2) ~ Contractor Code of 8usiflss Ethics and Conduct (Apr 2(10) (Pub. L. 110-252, Title VI,
Chapter 1 (41 U.S.C. 251 note))
_ (3) ~ Whisfle!)OY/ef Protections under the Arnerican Recovery and Reinvestment Act of 2009
(June 2010) (Section 1553 of PUb. L. 111-5). (Applies to contracts funded by the American Recovery and
]_ (4) 52.204-10, Reporting Execulive Compensation and First-Tier Sul:contract Awards (FEB 2012) (Pub
L. 109-282) (31 U.S.G. 6101 note)
_ (5) 52.204-11 American Recovery and Reinvestment Act-Reporting Requirements (JuI2010) (Pub. L.
111-5).
]_ (6) 52.209-6 Protecting tI1e Government's Interest When Sul:contracting with Contractors Debarred,
Suspended, or PrOp:lsed for Debarment (Dec 2010) (31 USC 6101 note)
]_ (7) 52.209-9, Updates of Publicly Availa!)e Informaton Regarding Resp:lnsibility Matters (FEB 2012) (41
US C. 2313).
_ (8) 52.2og-10, Prohibition on Contracting with tnverted Domestic Corporations (section 740 of Division C
of Pub. l. 111-117, section 743 of Division D of Pub. L 111-8, and section 745 of Division 0 of Pub. L 110-161).
(Q) 52.2193, Notice of HUBZone Set-Aside or Sole-Source Award (NOV 2011) (15 US.C. 657a)
(IO) 52.219-4, Notice of Price Evaluation Preference for HUBZone Small Business Concerns (JAN 2(11)
(~the ofIerorelects to waive the preference, ~ shall so indicate tl its offer) (15 USC 657a)
_ (II) (Reserved]
_ (12)(i) 52.219.0, Nofice of Total Small Business Set-Aside (NOV 2011) (15 U.S.C. 644).
_ Oil Memate I (NOV 2011)
_ Qii) A~emate II (NOV 2011).
_ (13Xij 52.219-7, Notice of Partial Small Business Set-Aside (June 2003) (15 USC 64 4)
_ Oi)Memate I (Oct 1995) of52.219-7.
_ Qii) A~emate II (Mar 2004) of 52.219-7
]_ (1 4) 52.219-8, Utilization of Small Business Concerns (Jan 2(11)
(3))
_ (15)(i) 52.219-9, Small Business Subcontracting Plan (Jan 2011)
_ (ii) Memate I (Oct 2001) of 522199
_ Qii) Memate II (Oct 2001) of 52.219-9
(iv) Atternate III (Jul2010) of 52.2199
_ (16) 52.219-13, Notice of Set-Aside of Orders (NOV 2011)(15 U.S.C. 644(r))
_ (17) 52.219-14, limitatioflS on Sulx:ontracting (NOV 2011) (15 U.S.C. 637(a)(14))
_ (18) 52.219-16,liquidated Damages-Sul:contracting Plan (JAN 1999) (15 U.S.C. 637(d)(4XF)(i))
_ (19Xi) 52.219-23, Notice of Price Evatuation Adjustment for Sman Disadvantaged Business Concerns
(OCT 2008) (10 U.S.C. 2323) (d the offeror elects to waive the adjustment, ~ shall so indicate in its offer).
_ Qi) Attemate I (JUNE 2(03) of 52.219-23.
_ (20) 52.219-25, Small Disadlrantaged Business Participation Program-Disadvantaged Status and
Reporting (DEC 2010) (Pub. L. 103-355, section 7102, and 10 U.S.C. 2323).
_ (21) 52.219-26, Smal D5advantaged Business Participation Program- tncentive Sul:contracting (OCT
2000) (Pub. L. 103-355, section 7102, and 10 U.S.C. 2323).
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_ (22) 52.219-27, Notice of ServiceDisa~d Veteran-Owned Small Business SetAside (NOV 201 1) (15
USC.657(f)
]_ (23) 52,21928, Post Award Small Business Program Representaton (APR 2012) (15 U.S.C. 632(a)(2)).
_ (24) 52.219-29, Notice of Set-Aside fo r Economically DisadvantagedWomen-O.Yned Small Business
(EOWOSB) Concerns (APR 2(12) (15 U.S.C. 637(m)).
_ (25) 52.219-30, Notice of Set-Aside fo rWomen-ONned Small Business ('WOSB) Concerns Eligible Under
the WOSB Program (APR 2012) (15 U,S,C. 637(m)).
]_ (26) 52,2223, Convict lalxlr (JUNE 2003) (E.O. 11755).
_X_ (27) 52.222-19, Child Lalxlr-Cooperation.,.,;th AuthoMties and Remedies (MAR 2012) (EO 13126)
]_ (28) 52.22221 , ProhiMion of Segregated Facilities (FEB 1999).
]_ (29) 52.222-26, Equal Opportunrty (MAR 20(7) (EO. 11246)
] _ (30) 52.22235, Equal Opportunity lor Veterans (SEP 2010X38 U,S.c. 4212)
]_ (31) 52.222-36, Affirmative Acton for Workers .,.,;th Disabilrties (OCT 2010) (29 USC. 793)
] _ (32) 52,22237, Employment Reports on Veterans (SEP 2010) (38 U,S.c. 4212).
]_ (33) 52.22240, Notification of Employee Rights Under the National labor Relations Act (DEC 2010)
(E,OI3496)
_ (34) 52.222-54, Empoyment Eligibility Verification (JAN 20(9). (Executive Order 12989). (Not applicable
to the acquisition of comrnercialy available off-the-sheH items or certain other types of commercial items as
prescMbed in 22,1803,)
_ (35Xi) 52.2239, Estimate of Percentage of Recovered Material Content for EPA-Designated Items
(MAY 2008) (42 U.S.C. 6962(c)(3)(A)(ii)). (Not applicable to the acquisition of commercially available off-the-she~
ijems,)
_ ~i) AHemate I (MAY 2(08) of 52.223-9 (42 US.C. 6962(i)(2)(C)) (Not applicable 10 the acquisition of
commercially ava~able off-the-shelf ~ems. )
_ (36) 52.223--15, Energy Efficiency in Energy-Consuming Products (DEC 2007) (42 U.S.C. 8259b)
_ (37Xi) 52.22316, IEEE 1680 Standard for the Environmental Assessment of Personal Computer Products
(DEC 20(7) (EO. 13423)
_ (ii) AHem ate I (DEC 2007) of 52.223--16.
_X_ (38) 52.22318, Encouraging Contractor Policies to Ban Text Messagillg While Driving (AUG 2(11) (E.O.
13513).
_ (39) 52.225-1 , Buy Amencan Act-8upplies (FEB 2009) (4 1 U.S.C, 10aIOd)
_ (40Xi) 52.225-3, Buy American Acl-Free Trade Agreements-Israeli Trade Act (MAR 2(12) (4t US.C
chapter83, 19 U.S.C, 3301 note, 19 U,S,C. 2112 note, 19 U.S.C. 3805 note, 19 U.S.C. 4001 note, PUb. l. 103-182,
Pub.l. 108-77, 10878, 108286, 108-302, 109-53, 109-169, 109-283, 110-138, and Pub. L 112-41)
_ (ii) Afternate I (MAR 2012) of 52.225-3
_ (iii) Alternate II (MAR 2012) of 52.225-3
(rv) AHernate II I (MAR 20t2) of 52.225-3
(41) 52.225-5, Trade Agreements (MAR 2(12) (19 U,S.C. 2501 , et seq., 19 US.C, 3301 note).
J_ (42) 52.225-13, RestrictioflS on Certain Foreign Purchases (JUNE 2008) (EO.'s, proclamations, and
statutes administered by the Office of Foreign Assets Control of the Department of the Treasury).
_ (43) 52.226-4, Notice of Disaster or Emergency Area Set-Aside (NOV 2007) (42 U.S.C. 5150)
_ (44) 52.225-5, Restrictions on Subcontracting Outside Disaster or Emergency Area (NOV 2007) (42
U,S,C. 5150).
_ (45) 52.232-29, Terms for Financing of Purchases of Commerciaillems (FEB 2(02) (41 USC 255(f),
10US.C, 2307(f)).
_ (46) 52.232-30, Installment Payments for Commercial Items (OCT 1995) (41 US.C. 255(f), 10 US.C
2307(Q).
J_ (47) 52.23233, Payment by Electronic Funds Transfer-Central Contractor Registration (OCT 2003)
(31 U.SC. 3332)
_ (48) 52.232-34, Payment by Electronic Funds Transfer-Olherlhan Central Contractor Registration
(MAY 1999) (31 US.C 3332)
_ (49) 52.232-36, Payment by Third Party (FEB 2010) (31 U.S.C. 3332)
_ (50) 52.239-1, Privacy or Security Safeguards (AUG 1996) (5 U.SC 552a)
_ (51)(i) 52.247-<34, Preference for Privately OMled
_ (ii) Anernate I (Apr 2003) of 52.247-<34
(c) The Contractorshall comply.,.,;th the FAR clauses in this para9raph (c), applicable to commercial
services, that the Contracting Officer has indicated as being incorporated in th is contract by reference to implement
provisions of lawor ExecutM! orders appl;::able to acquisitions of commercial ~ems:
_ (1) 52,222-41, Service Contract Act 0( 1965, (Nov 2(07) (4 1 U.S.C, 351 , el seq.~
_ (2) 52.222-42, Statement of Equivalent Rates for Federal Hires (May 1989) (29 U.S.C 206 and
41 U,S,c. 351, ef seq.)
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_ (3) 5?n2-43 , Fair labor Standards Act and Service ContractAct-Price Adjustment (Multiple Year and
Optioo Contracts) (Sep 2009) (29 USC. 206 and 41 US.C 351 et seq.)
_ (4) 52 222-44, Fair labor Standards Act and Service Contracl Act-Plice Adjustment (Sep 2009)
(29 US.C 2oo and 41 US.C 351 el seq.)
_ (5) 52.222-51 Exemption from Appijcation of tMe Service Contract Act to Contracts for Maintenance,
Calibration, or Repair 01 Certain Equip:nent-Requirements (Nov 2007) (41 U,S,C. 351 et seq.)
_ (6)~, Exemption from Application of IMe Service Contract Act to Contracts for Certai1 ServicesRequirements (Feb 2009) (41 U.S.C 351 et seq,)
_ (7) 52_ 226~ Prorrotng Excess Food Donatioo 10 NonprofilOrganizalions (Mar2009) (Pub. l. 110-247)
_ (8) R2E:1.1. Accepting and Dispensing or SI Coin (Sept 2008) 11' USC. 5112{pl!ll)
(eI) Comp/ro/JerGenera/ Examinal~n of Record. The Contractor shall comply with the provisions oflhis
paragraph (d) if this contract was awarded using olher than sealed bid, is in excess of the s i mjll~ied acquisition
threshold, and ooes not contain the clause at 52.215.2, Audit and Records-Negotiatioo
(I) The ComptrollerGeneral of the United States, or an authorized representative olthe Comptroller General,
shaD have access to and right to examine any of Ihe Contractor's directly pertinent records invoMng transactions
related 10 this contracl
(2) The Contractor shall make available at its offices at all reasonable times the records, materials, and other
evidence IOf examination, audit, or reproduction, unlil 3 years after fina l p!ymenl under this conlract orlor any shorter
period specified in FAR Subp!rt 4.7, Contractor Records Retention, of the other clauses of this contract, If this
contract is completely or p!rtialty terminated, the records relating to the mrk terminated shall be made available for
3 years after any resulting final termination settlement Records relating to appeals under IMe disputes clause or to
I~igation or the settlement of claims arising under or relating 10 this contract shall be made available until such
appea ls, l~igalioo , Of claims are finally resolved
other data, regardless of type and regardless of form This does not require the Contractorto creale Of maintain any
record thatlhe Contractor does not maintain i1 ttle ordinary course of business or pursuant to a jXOvision of law.
(e)(I) Notv.ithstanding the requirements of the cIa uses in paragraphs (a), (b), (c), and (d) of this clause, the
Contraclor is not required to flow dcwn any FAR dause, other than those in paragraphs (e)(I)(i) through (xi) of this
paragraph ., a subcontract for commercial items. Unless otherwise indicated bebw, the extent of the flowdcwn shal
be as required by the clauseW)52203-13, Contractor Code of Business Eth(:s and Conduct (Apr 2010) (Pub. L. 110-252, Title VI,
Chapter 1 (41 USC 251 notel)
(iij 52.219-8 Utilization of Small Business Concerns (Dec 2010) (15 U,SC. 637(d)(2) and (3l), in all
subcontracts that offer further subcontracting opportunrties. If the subcontract (except subcontracts to smal rosiness
concems) exceeds $650,000 ($1 .5 million fo r construction of any public facility), the subcootractor mllSt include
~ in lo-wertier subcontracts that offer subcontracting opportunities
(iii) [Reserved)
(Iv) 52.222-26 Equal Opportunity (Mar 2007) (E.O. 11246).
(v) 52222-35, Equal Opportunity fo r Veterans (Sep 2010) (38 U.SC 4212)
(vi) 52.222-36 Affirmative Action for Workers with Disabnities (Oct 2010) (29 U.S.C. 793).
(vii) 52.222-40 Not~ication of Employee Rights Under the National Laixlr Relabons Act (Dec 2010) (E.O.
13496). FICIw down requ~ed in accordance with paragraph (f) of FAR clause 52.222-40.
(vii) 52.222-41 Service Conlract Act of 1965 (Nov2007) (41 USC. 351 el seq.)
(ix) 52.22250, Combating Trafficking in Persons (Feb 2009) (22 U.SC. 7104(gl)
_AHernate I (Aug 2007) of 52222-50 (22 USC. 71041g)).
(x) 52.22251 Exemption from Application oflhe Service ContractAct to Contracts for Maintenance,
Calibration, or Repair of Certain EquipmentRequirements (Nov 2007) (41 U.S.C 351 el seq.)
(xi) ~, Exempl:ion from Appication olthe Service Contract Act to Conlracts for Certain ServicesRequirements (Feb 2009) (41 US.C 351 et seq.)
(xii) ~, Employment Eligibi l ~y Verif(:ation (JAN 2009)
(xiii) 52.226-6 Promoting Excess Food Donation to Nonprof~Organjzalio n s (Mar 2009) (Pub l. 110-247)
Flowdown required in accordance with paragraph (e) of FAR clause 52.226-6.
(xiv) 52. 247~4 Preference for Privalely OMled U.S.-Flag Commercial Vessels (Feb 2006) (46 U.SC
Appx. 1241(b) and 10 U,S.C. 2631), Flow dcwn required in accordance with paragrapll (d) of FAR
clause52247~4
(2)While not required, the contractor may include in ~s subcontracts for commercial ~ems a minimal number
of add~ional clauses necessary to sausfy its contractual obl9ations
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CONTRACT DOCUMENTS, EXHIBITS, AND ATTACHMENTS

DOCUMENTlEXHIBITI ATTACHMENT TITLE
Attachment 1 11)0 Price Sciledule

IPPWaiver Form
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CONSUMER FINANCIAL PROTECTION BUREAU
INDEFINITE.QELlVERY INDEFINITE~UANTITY (IDIQ) STATEMENT OF WORK
CONSUMER CREDIT INFORMATION PANEL
1.(1
BACKGROUND
The Dodd.frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) established the
Consumer Financial Protection Bureau (CFPS)
The Cllntral mission ofllle CFPB is to make markets for consumer financial products and services work for Americans
-whether they are applying for a mortgage, choosing among credrt cards, or using any number of otr.erconsumer
financial products,
The CFPS is workir.g to give consumers lIle information they need to understand lIle terms of their agreements with
financ ial companies CFPS is working to make regulations and guidance as clear and streamlined as possible so
providers of consumer financial products and services can Mow the ru les on theirown.
Congress established the CFPB to protect consumers by carrying out Federal consumer financia l laws Amor.g olller
lIlings. CFPS:
Conducts ru le-making, supervision, and enforcement for Federal consumer financ ial protectioo laws;
Restricts unfair, deceptive, or abusive acts or pract,=:es;
Takes consumer complaints;
Promotes financial education;
Researches consumer behavior,
Monrtors financial markets for new risks to corlSumers; and
Enfortes laws lIlat outlaw discrimination and olllel unfair treatment in consumerfinanCll
2,
OBJECTIVE
The CFPS seeks to acquire and maintain a nationally representative panel of credrt i:1formation on consumers for use
in a wide range of policy research projects
The panel shall be a random sample of consumer credit files attained from a national database of credit files. The
Contractor shall provide an initial panel of consumers with htstorical information on a quarte~y basts, The Contractor
shall provide an initial panel lllat goes back 10 years. Goingforward, the Contractor sJ'la11provide updated consumer
credit files for the consumers in the database on a quarterly basis
3.0
SCOPE
3,1
Panel Description' The Contractor sJ'la11provide a nationally representative panel of consumers with
consumer reporting information. The panel may be stralif~d atthe regional or state lewl, as delermined by lIle CFPS
in consultation 'MIh the Contractor. If the sample is stratified, the Contractor shall provide lIle CFPB with information
about the size of various populations within the Contractor's database such that the CFPS may construct weights to
make lIle sample nationaly representative. The sample may be created either by sampUng at the consumer level or
lIle household level, as determined by the CFPS in COrlSultation with the Contractor. lIthe sample is constructed at
lIle household level, the Coillractor shall provide the CFPB with information about the size of various populations
within the Contractor's dataoose such that the CFPS may construct weights to make the sallllie representative at the
individual levet The Contractor shal have lIle capability of including joint borrawers, co-signers, and authorized users
as part of lIle panel. The panel sJ'la11include 5 million consumers, and Joint borrowers, co-signers, and authorized
users. The initial panel shall contain 10 years of h5torical data on a quarte~y baS5. The in ~ial sample shall be drawn
from current records and historical data appended for that sample as well as additional samples during the intervening
years to make lIle combined sample representative at each point in time
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3.2
Panel Updales
~
~
3.3
The Contractor shall provide quarterly updales. The Conlractor stlall have capaDlity of providing account
information. such as accoont balances. for lIle intervening monllls
The Contractor shall be able to maintain representativeness ofllle panel OWlr ~me, willl respect to the
Conlractor's primary credrt history database, such as through sampling new credit files and appending those
samples to lIle panel. The Contractor shall deWlklp, in consu~ation withlIle CFPS a methodology lor
periodically testing the representativeness on the panel.
Data Chara cteristics
The panel shall contain the contents of the select consumers' credit files except lor data elements such as
name, address, full account number, lIlat need to be masked to preserve confidentiality. The Contractor shall
provide ZIP+4. or other geographic location information such as Census block identifier. and age or year 01
birth, wtl en available.
~ For each consumer in the panel, the Contractor shall provide credit scores as requested by the CFPB.
>- The Contractor shall provide a persistent consumer identifier making it IXlssibie to fol low consumers oWlrtime
inlIle panel The Contractor shall proYKIe a persistent trade line identifier making it pos sible to folklwtrade
lines OYer time in the panel.
The Contractor does not need to identify the fumisher/cred~or of particular trade lines, unless an approach to
provid ing this information that is acceptable to the Contractor and the CFPB can be found. The Contractor
shan, howeWlr, provide a means to identify wtlich trade tines come from the same fumisher1creditor, across
consumer files
> The contractor shall provide non-credit demograp(1ic information about the consumers in the panel.
~
Capabilities
3.4
~
The Contractor shall conduct surveys on particular products and subsets of consumers from the credit panel.
>- The Contractor shall provide non-credit attributes to be i1cluded with their panel
~ The Contractor shall design the panel so ~ can be linked to external data sets including demographic data
3.5
Consu ~i ng
The panel shall be fu lly supported by the Contractor's in-house data experts
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Q.15. Please provide a copy of a representative data request that
the CFPB has sent to financial institutions and others involved in
the Bureaus consumer data collection efforts.
A.15. Any communications between the CFPB and a supervised financial institution or a Federal, State, or foreign Government
agency related to the CFPBs supervision of the institution is confidential supervisory information. 12 CFR 1070.2 (i)(1). Consequently, specific supervisory requests for information are subject
to the prohibition against disclosure of confidential supervisory information set forth in 12 CFR 1071.41.
However, the Bureau uses a number of standard form information requests as part of its examinations. See, Compliance Management System Information Request, attached. Examiners modify these requests to customize them to the particular institution.
In the information request, examiners are instructed to specify the
review period and the information or documentation required, in
order to reduce the burden on the institution and avoid receiving
data not relevant to the examination. See page 6 of the CFPBs Supervision and Examination Manual, Examinations (Prepare and
Send
the
Information
Request)
(available
at
http://
files.ConsumerFinance.gov/f/201210lcfpblsupervision-and-examination-manual-v2.pdf).
The Bureau avoids receiving personally identifiable information
whenever possible. The Bureau protects all confidential supervisory
information in accordance with the regulation governing the Bureaus handling of confidential information, 12 CFR Part 1070.
Q.16. Has the CFPB conducted any cost-benefit analysis to determine the cost of the data collection requests and production on the
institutions? Has the CFPB solicited feedback from any institutions
about the cost of these data collection requests and production?
A.16. The Bureau does not conduct an explicit cost-benefit analysis
of supervisory data requests made in support of the examination
function, as those requests are tailored to be consistent with the
scope of information appropriate to carry out the purposes of supervisory activity. Pursuant to sections 1024(b) and 1025(b) of the
Dodd-Frank Act, the Bureau coordinates its examinations with the
prudential regulators and the State bank regulatory authorities;
and, to the extent possible, the Bureau uses reports provided or required to be provided to Federal or State agencies. Both practices
tend to reduce the cost of supervisory activities. The Bureau also
routinely discusses its supervisory information requests with supervised entities in advance in order to make the best use of existing
data formats and content, decreasing the burden to supervised entities of providing information requested by the Bureau. These
interactions provide insight about how to acquire information efficiently.
On occasion, the Bureau has also obtained data outside the supervisory process. The information has all been provided on a voluntary basis, and the Bureau believes the companies that provided
this information attempted to do so in an efficient and cost-effective
manner. For example, in connection with the Private Student Loan
Report required by section 1077 of the Dodd-Frank Act, the Bureau
met with major participants in the private student loan industry
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and offered them the opportunity to provide data on several of the
16 questions that Congress required the Bureau to answer. Nine
lenders volunteered to provide their existing datasets to a single
vendor that they selected. This vendor combined those data into a
single database that did not include the identities of borrowers or
lenders. This mechanism was an efficient way for the lenders and
the Bureau to develop answers to Congress questions. Both the
Bureau and the lenders continue to utilize that dataset to provide
information to the public, to Congress, and to regulators about that
industry.
In some instances, the Bureau has requested financial institutions to provide a random sample of de-identified records rather
than a full file. Sampling may add some cost to the financial institution but reduces the cost to the Bureau in handling larger files.
In other instances, especially those involving ongoing data collections, the Bureau has determined that it would be more efficient
for the financial institution to provide a full, de-identified file to the
Bureau rather than requiring that sampling frames be created
each time new data is provided.
Q.17. In your testimony, you cite that GAO conducts an annual
audit of the agency. Does the GAO specifically audit the Big Data
collection undertaken by the CFPB? Does GAO audit the specific
contracts of the outside, third-party vendors and their contractors
hired by the CFPB for the collection of Big Data? Does GAO conduct any peer review of any research done using the Big Data?
A.17. The GAO has not conducted an audit focused on the specific
subject of data collection by the Bureau or Bureau contracts for
such collection. However, the GAOs and Inspector Generals audits
and evaluations of the Bureaus budget, information security, and
implementation of the Dodd-Frank Act, among other subjects, address myriad aspects of the Bureaus contracting and information
collection, storage and usage activities. The GAO has not conducted
any peer review of Bureau research, to the Bureaus knowledge.
Q.18. The CFPB issued a rule with regard to remittances to foreign
countries last year, which the Bureau has updated on a couple of
occasions since its issuance. The final rule on remittances contains
a specific error resolutions procedure for remittance transfers.
However, a recent blog posting by the Bureau suggested the CFPB
will begin accepting consumer complaints on money transfers without distinguishing between foreign and domestic transfers. Is the
blog posting a change in direction for the Bureau? Does the Bureau
consider posting to its blogs as regulatory guidance or just an informational venue? Has the Bureau reached out to the industry to inquire what effect such blog postings have on the industry practices?
A.18. Section 1073 of the Dodd-Frank Act amends the Electronic
Fund Transfer Act to add a new provision governing remittances
to foreign countries. One part of that amendment requires remittance transfer providers to resolve certain errors raised by consumers with respect to such remittances. Another part of the
amendment requires remittance transfer providers to inform consumers of their rights concerning error resolution and of the Bureaus contact information, including its toll-free consumer com-
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plaints number. The Bureau has issued implementing regulations
as required by 1073 (the Remittance Transfer Rule).
Separately, 1013(b)(3) of the Dodd-Frank Act establishes within
the Bureau . . . a unit whose functions shall include establishing
a single, toll-free telephone number, a Web site, and a database or
utilizing an existing database to facilitate the centralized collection
of, monitoring of, and response to consumer complaints regarding
consumer financial products or services. Collecting, investigating,
and responding to consumer complaints are integral parts of the
Bureaus work.
In March 2012, the Bureau began accepting complaints about
many types of bank and credit union products and services, including domestic money transfers and money transfers that will qualify
as remittance transfers under the Remittance Transfer Rule
when it takes effect on October 28, 2013, as well as the wide range
of other types of products and services that these institutions offer,
such as checking accounts and loans. In April 2013, the Bureau
launched a money transfer-specific complaint form to accept complaints concerning entities other than banks and credit unions
about domestic money transfers, as well as transfers that will qualify as remittance transfers.
The purpose of the blog posting dated April 4, 2013, and titled
Now accepting money transfer complaints (available at http://
www.ConsumerFinance.gov/blog/now-accepting-money-transfercomplaints/), was to announce to consumers that the Bureau was
now accepting these types of complaints through a dedicated complaint form. The blog provides consumers with a link to the form
and lets them know what information they should have available
before submitting a complaint. The blog post does not represent a
change in direction for the Bureau; it is consistent with our use of
the blog to engage and inform the public about Bureau activities
and is not intended as legal guidance.
The Bureau has engaged and will continue to engage with industry regarding its intake of money transfer complaints and welcomes
feedback regarding the blog post. Similarly, the Bureau has
reached out to industry and will continue to do so regarding the
impact of the Remittance Transfer Rule.
RESPONSES TO WRITTEN QUESTIONS OF
SENATOR MENENDEZ FROM RICHARD CORDRAY
Q.1. I held a hearing this month looking at some of the mortgage

servicing abuses and the settlements that resulted. I was pleased
to see the CFPB adopted new rules related to mortgage servicing
standards in January 2013. I have long advocated for increasing
consumer protections on borrowers before foreclosures, encouraging
loan modifications, eliminating dual tracking, placing limits on
foreclosure fees, and creating an appeals process for those denied
loan modifications as well as a mediation program. Please detail
some of the specific requirements as they relate to:
Mortgage servicers providing information about mortgage loss
mitigation options to delinquent borrowers.
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Establishing policies and procedures for providing delinquent
borrowers with continuity of contact with servicer personnel
capable of performing certain functions.
A.1. The mortgage servicing rules issued by the Bureau provide
protections that seek to ensure that troubled borrowers receive a
fair process to avoid foreclosure wherever possible. Most notably,
the mortgage servicing rules include restrictions on the process of
dual tracking; i.e., the consideration of a borrower for a loss mitigation option while pursuing a foreclosure process. The rules further include requirements for evaluating timely and complete loss
mitigation applications for loss mitigation options.
Even before the loss mitigation evaluation occurs, however, the
Bureau has adopted requirements that will assist borrowers with
the process of understanding and applying for loss mitigation options. First, the mortgage servicing rules include early intervention requirements that apply early in the loss mitigation process.
The rules require servicers to reach out to borrowers about loss
mitigation options early in a delinquency. Specifically, servicers are
required to make good faith efforts to establish live contact with a
delinquent borrower not later than the 36th day of a borrowers delinquency and promptly inform such borrower about the availability of loss mitigation options if appropriate. Further, not later
than the 45th day of delinquency, a servicer must provide a written
notice to the borrower that includes, among other things, information about any loss mitigation options available to the borrower
and how to apply for such options, information about contact personnel assigned to assist the borrower, and information regarding
other resources that may be available to assist the borrower with
loss mitigation options, such as housing counselors or organizations.
This is designed primarily to encourage delinquent borrowers to
work with their servicers to identify their options for avoiding foreclosure. The Bureau recognizes that not all delinquent borrowers
who are contacted by their servicer and receive a written notice
will respond to the servicers and pursue available loss mitigation
options. However, the Bureau believes that the notices will ensure,
at a minimum, that all borrowers have an opportunity to do so at
the early stages of a delinquency.
That is just the beginning of the process. The Bureaus rules further require that servicers must have policies and procedures in
place to provide delinquent borrowers with direct and ongoing accessthe term of art is continuity of contactto personnel who
are responsible for helping struggling borrowers. Such personnel
must be assigned to assist a borrower by the time the early intervention written notice is provided, and in any event, no later than
the 45th day of a borrowers delinquency. The servicers policies
and procedures must be reasonably designed to ensure that such
personnel are able to provide information to the borrower about
available loss mitigation options, the application process for such
options, the status of any loss mitigation application submitted by
a borrower, any applicable loss mitigation deadlines, and when a
foreclosure process may begin. Further, the servicers policies and
procedures must be reasonably designed to ensure that such personnel have access to a complete record of the borrowers payment
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history and information provided by the borrower regarding loss
mitigation, that such personnel are able to provide this information
to servicer personnel responsible for evaluating a borrower for loss
mitigation options, and that such personnel can provide a borrower
with information about the procedures for submitting a written notice of error or information request.
Q.2. In June 2012, the CFPB announced that it would be the first
Federal financial regulator to share with the public individual consumer complaint data. They are accepting consumer complaints in
many areas, including checking accounts, savings accounts, CDs,
credit cards, credit reporting, money transfers, mortgages, student
loans, and consumer loans. How many complaints has the CFPB
received from consumers so far about mortgages, credit cards,
banks, debt collection, and other financial services? How many of
those are being resolved successfully, and in what ways?
A.2. The Bureau began accepting consumer complaints about credit
cards on July 21, 2011. The Bureau now also accepts complaints
related to mortgages, bank accounts and services, private student
loans, other consumer loans, credit reporting, and money transfers.
From July 21, 2011, through February 28, 2013, the Bureau received approximately 131,300 consumer complaints, including approximately 30,600 credit card complaints, 63,700 mortgage complaints, 19,800 bank accounts and services complaints, 4,600 private student loan complaints, 4,100 consumer loan complaints, and
6,700 credit reporting complaints. The Bureau has received some
money transfer complaints through the bank accounts and services
intake form. In April 2013, the Bureau introduced a money transfer-specific intake form. Data from those complaints is preliminary.
Data are also not available about debt collection or payday complaints because the Bureau does not accept these complaints at this
time. The Bureau, however, continues to work toward expanding
its complaint handling capacity to include other products and services, such as payday loans and debt collection.
More than 109,200 complaints (83 percent of complaints) received as of February 28, 2013, had been sent by the Bureau to
companies for review and response. The remaining complaints had
been referred to other regulatory agencies (11 percent), found to be
incomplete (3 percent), or were pending with the consumer or the
Bureau (3 percent). Companies had already responded to approximately 104,100 complaints or 95 percent of the complaints sent to
them for response. Consumers had disputed approximately 19,600
company responses (21 percent) to complaints.
As of February 28, 2013:
Credit card complaints: Approximately 27,700 (84 percent)
credit card complaints had been sent by Consumer Response to
companies for review and response. The remaining credit card
complaints had been referred to other regulatory agencies (10
percent), found to be incomplete (5 percent), or pending with
the consumer or the Bureau (one percent). Companies had already responded to approximately 24,800 complaints or 96 percent of the complaints sent to them for response. Since December 2011, companies have had the option of reporting the
amount of monetary relief, if any. The median amount of relief
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reported was approximately $125 with $25 being the most common amount of relief for the approximately 5,300 credit card
complaints where companies reported relief. Consumers had
disputed approximately 4,200 company responses (18 percent)
to credit card complaints.
Mortgage complaints: Approximately 56,800 (89 percent) mortgage complaints had been sent by Consumer Response to companies for review and response. The remaining mortgage complaints had been referred to other regulatory agencies (7 percent), found to be incomplete (1 percent), or pending with the
consumer or the Bureau (2 percent). Companies had already
responded to approximately 53,900 complaints or 95 percent of
the complaints sent to them for response. The median amount
of monetary relief reported was approximately $425 for the approximately 1,800 mortgage complaints where companies reported relief. Consumers had disputed approximately 10,500
company responses (23 percent) to mortgage complaints.
Bank account and services complaints: Approximately 16,100
(81 percent) bank account and service complaints had been
sent by Consumer Response to companies for review and response. The remaining bank account and service complaints
had been referred to other regulatory agencies (14 percent),
found to be incomplete (4 percent), or were pending with the
consumer or the Bureau (1 percent). Companies had already
responded to approximately 15,500 complaints or 97 percent of
the complaints sent to them for response. The median amount
of monetary relief reported was approximately $110 for the approximately 4,000 bank account and service complaints where
companies reported relief. Consumers had disputed approximately 3,000 company responses (20 percent) to bank account
and service complaints.
Private student loan complaints: Approximately 3,400 (74 percent) private student loan complaints had been sent by Consumer Response to companies for review and response. The remaining private student loan complaints had been referred to
other regulatory agencies (20 percent), found to be incomplete
(4 percent), or pending with the consumer or the Bureau (2
percent). Companies had already responded to approximately
3,200 complaints or 94 percent of the complaints sent to them
for response. The median amount of monetary relief reported
was approximately $1,250 for the approximately 225 private
student loan complaints. Consumers had disputed approximately 600 company responses (19 percent) to private student
loan complaints.
Consumer loan complaints: Approximately 2,600 (63 percent)
consumer loan complaints had been sent by Consumer Response to companies for review and response. The remaining
consumer loan complaints had been referred to other regulatory agencies (30 percent), found to be incomplete (3 percent),
or pending with the consumer or the Bureau (4 percent). Companies had already responded to approximately 2,400 complaints or 95 percent of the complaints sent to them for response. The median amount of monetary relief reported was
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approximately $195 for the approximately 240 consumer loan
complaints. Consumers had disputed approximately 500 company responses (23 percent) to consumer loan complaints.
Credit reporting complaints: Approximately 4,300 (64 percent)
credit reporting complaints had been sent by Consumer Response to companies for review and response. The remaining
credit reporting complaints had been referred to other regulatory agencies (4 percent), found to be incomplete (3 percent),
or is pending with the consumer or the Bureau (28 percent).
Companies had already responded to approximately 3,900 complaints or 90 percent of the complaints sent to them for response. Consumers had disputed approximately 600 company
responses (19 percent) to credit reporting complaints.
Q.3. At your confirmation hearing this year, I submitted questions
for the record having to do with balancing the need for consumer
protections and access to short term credit and building creditworthiness. As part of your response, you referenced the need to
learn about the potential for innovation in financial products. A
question that has not been answered is if nondepository short term
lending is curtailed or eliminated, what products will take their
place for underserved consumers? Can you update me on your efforts to address this issue and what is the status of the CFPBs
analysis of how to solve the growing problem of access to short
term credit?
A.3. The Bureau recognizes that there is a need for access to small
dollar credit to handle occasional emergencies. But such loans can
be harmful when they are poorly structured. For example, extremely short-term creditmeaning that the loan is structured so
that the consumer has to repay the loan in a very short period of
timecan be harmful to consumers. Furthermore, most small-dollar, short-term loans available to consumers now do not build creditworthiness.
In light of these concerns, we strongly encourage consumers to
explore their full range of options when dealing with a financial
shortfall. We encourage consumers to consider less expensive credit
options, particularly if they have an account at a bank or credit
union or a stable credit history. Credit cards, advances, or emergency credit offered by employers, nonprofit organizations, and
community groups are other options. Other options might include
negotiating with the creditor or biller about the debt or bill they
owe before resorting to a payday or deposit advance loan.
Q.4. You stated in your answers to my questions that the CFPB
is determining which product structures and features may curtail
sustained use and negative outcomes. Has the CFPB made any inroads since then on this issue? Assuming the CFPB has or does
identify negative outcomes and a product structure or feature that
it believes may mitigate negative outcomes, how would the CFPB
seek to require that product structure or feature of market participants?
A.4. This past month, the Bureau released a white paper on payday loans and deposit advance products, which examined patterns
of sustained use. We found that the median payday loan borrower
engages in 10 such transactions per year and is indebted a median
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of 199 days of the year, while more than half of all deposit advance
borrowers end up borrowing more than $3,000 per year in advances
and are indebted more than 40 percent of the year. However, we
found that these products may be appropriate for some consumers
for whom an expense needs to be deferred for a short period of
time. The key for the product to work as structured, however, is
a sufficient cash flow which can be used to retire the debt within
a short period of time.
The data presented in this study suggest some consumers use
payday loans and deposit advances at relatively low to moderate
levels. Thirteen percent of payday borrowers in our sample took out
only 12 loans over the 12-month period, and about one-third took
out six loans or less. A similar share of deposit advance users (30
percent) took no more than a total of $1,500 in advances over the
same period of time. We hypothesize that the lack of underwriting
and the single payment structure may be contributing to these patterns of sustained use.
We are currently undertaking additional analyses to see how outcomes vary under various State regulatory approaches, such as limits on maximum loan amounts or efforts to extend the period of the
loan. We will evaluate whether these and other approaches may
counter the effects of the traditional balloon payment structure
that might lead consumers to quickly reborrow. Our current analysis seeks to determine the drivers of consumer harm, while also
accounting for why some consumers are able to use these products
in an appropriate way (for example, paying the full amount back
when loan is due without having to reborrow).
Q.5. Has the CFPB considered the implications of providing a Federal platform to regulate online short term lending in a manner in
which some have argued that technology and the market can drive
innovative new products for underserved consumers and help them
build back their creditworthiness? For example, has the CFPB
looked at the pros and cons of a model that provides for partnerships between banks and nonbanks to offer OCC or FDIC chartered
financial products with CFPB consumer protections?
A.5. The Bureau has not analyzed all of the proposals to provide
Federal charters for nondepository financial service companies, and
we generally do not comment on proposed legislation. Bureau staff
does provide technical advice on specific provisions when requested
by Congress. We do note that some of the bills we have reviewed
have taken a very strong position in preempting all forms of State
consumer protection of small dollar borrowersmoving all authority to regulate both charter issuance and consumer financial protection issues to Federal regulators. The States have invested substantial legislative and regulatory energy over many years in
crafting protections that they view as appropriate for their consumers, so it would be a significant shift in public policy to sweep
those protections aside.
RESPONSES TO WRITTEN QUESTIONS OF SENATOR HAGAN
Q.1. The Nationwide Mortgage Licensing System (NMLS) and Registry provides a single system for the licensing and registration of
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the Nations mortgage industry. The System allows the States to
track mortgage loan originators from State-to-State on a nationwide basis. State regulators have begun using NMLS as the licensing platform for other regulated nondepository financial services
providers.
Would you agree that it would be beneficial to extend the privilege and confidentiality protections for mortgage-related information contained in the NMLS and which is shared by State and Federal regulators, to information in the NMLS relating to all other
types of nonbanks?
A.1. The Bureau is committed to establishing and maintaining productive working relationships with State bank and nonbank regulators and understands the importance of protecting the confidentiality of information that may be shared through such coordination
efforts. To this end, the Bureau has entered into information-sharing and cooperation MOUs, requiring the safeguarding of confidential information, with most State bank and nonbank regulators.
Moreover, the Bureau recently entered into a State Coordination
Framework to establish a process for coordinated Federal/State
consumer protection supervision and enforcement of entities providing consumer products or services that are subject to concurrent
jurisdiction of the Bureau and one or more State Regulators.
The Bureau believes that steps to better facilitate the sharing of
information among regulators by extending the confidentiality safeguards and privilege protections applicable to information placed in
the Nationwide Mortgage Licensing System to additional nonbank
activities could potentially be beneficial. We would be pleased to
look at any specific proposal and provide technical assistance.
Q.2. According to a Federal Trade Commission Report released in
December, at least 5 percent of consumers had errors in their credit scores that could lead them to pay higher rates for loans.
With the CFPBs supervision of credit reporting companies beginning last year, do you believe that the appropriate controls are in
place to the reduce the occurrence of errors?
What steps are being taken to reduce the occurrence of these errors and improve the process of error correction?
A.2. The Bureaus authority to supervise larger consumer reporting
agencies became effective in the fall of 2012. Among the Bureaus
first priorities has been to understand and evaluate the mechanisms used by consumer reporting agencies to collect consumer
data furnished by industry, compile and match that data to individual consumer files, and then deliver that data to users in the
form of consumer reports. The Bureaus White Paper on Key Dimensions and Processes in the U.S. Credit Reporting System describes the Bureaus initial insights into how the industry handles
data. For example, in the report, the Bureau observed the limitations of the existing e-OSCAR dispute handling system, which does
not forward the documents consumers attach in their complaints to
furnishers.
Through our Supervision program, which is in its early stages,
we now have the opportunity to examine the larger consumer reporting agencies to assess their compliance with the Fair Credit
Reporting Act and other Federal consumer financial laws. Our re-
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views will help us to evaluate the question you askare the controls in these companies appropriate to reduce errors. This issue is
one we are focusing on in our review of consumer reporting agencies.
Q.3. During your testimony you mentioned that the Bureau has addressed the issue of indirect auto lending in a very general way
with a legal analysis and that it has not reached a factual conclusion about any particular instance. Can you describe the process
through which the CFPB would move from a legal analysis to a factual conclusion? What types of statistical tools and proxies might
be available to the Bureau to address data gaps and identify different groups of consumers?
A.3. These questions about methodology and analysis are critical to
the Bureau. As a data-driven organization, we want to be sure that
our analysis of the auto finance industry is based on current and
solid facts about the industry, its business practices, and its participants. In the past year, Bureau representatives have met with
numerous individual lenders, auto lender associations, and dealer
associations to learn about the industry and the statistical tools
and proxies that industry uses to self-monitor its lending activity
for fair lending risk.
The Bureaus ongoing supervision program enables it to examine
fair lending compliance by many indirect auto lenders. We have enforcement authority over indirect auto lenders as well. The Bureau
uses a variety of methods to identify legal violations and the choice
of technique will often depend on the facts and circumstances. In
the fair lending context, some violations can be determined by reviewing the text of an entitys policies, while other violations are
determined using other additional methods, like comparative file
reviews or statistical analyses.
Demographic information, such as race, sex, and ethnicity, are
generally not collected by nonmortgage lenders but are vital to assessing fair lending compliance. Thus, Federal regulatory and enforcement agencies have long used proxy methods in nonmortgage
data analyses. These methods are well accepted by economists and
by regulators. Like other agencies, the Bureau also uses proxies for
demographic characteristics. We have made clear that we base our
proxies on publicly available data. For example, as a proxy for sex
we use data on first names published by the Social Security Administration. For race and ethnicity, we use both surname and geographical data published by the Census Bureau. Various proxy
techniques are publicly available in academic research, and we encourage indirect auto lenders to select a reasonable method and
begin to examine their data, if they have not done so already.
RESPONSES TO WRITTEN QUESTIONS OF SENATOR MORAN
Q.1. The proposed rule to combine mortgage disclosures required

by RESPA and TILA includes a requirement that consumers receive their closing disclosure 3 days before they actually close on
their home. The proposed rule requires a second 3-day waiting period if there are any changes within 3 days of the scheduled closing. The proposed rule has very narrow exceptions for these last
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minute changes. There are a lot of changes that can happen right
before closing, sometimes the day of the closing on a final walk
through of the property. Without flexibility in the regulation, retriggering a second 3-day waiting period could cause frustrating,
costly and unwanted delays for consumers. A delay could cause
higher costs, higher fees, lost deposits or earnest money if the real
estate contract requires the deal to close by a certain date and lost
interest rate lock. In situations where the consumer is going to be
hurt financially or otherwise harmed or perhaps they do not desire
a second 3-day delay, how can consumers be given more flexibility
to avoid these costly delays?
A.1. Based on what we have heard from consumers, lenders, and
settlement agents, everyone is frustrated with the way closings are
conducted today. One major source of this frustration is that consumers are first presented with certain critical information about
their loans at the closing table. The proposal we are considering
would require that consumers receive the final disclosure at least
3 days before closing, so they have the time to review the disclosure in an unpressured environment. This is intended to ensure
that all consumers have time to review, question, and understand
their transaction before they have to sign on the dotted line.
We understand, however, that sometimes things will change during the 3-day period between disclosure and closing. We also understand that not all changes justify delaying the closing date. Therefore, we proposed several exceptions specifying situations that
would not trigger a second 3-day waiting period. One of these exceptions is for buyer and seller negotiations. For example, when a
home is being purchased, the buyer typically performs a walkthrough inspection the day before the closing. If the buyer identifies repairs that need to be made, the buyer and seller may negotiate a change in the transaction to cover the cost of those repairs.
Our proposal would not delay the closing for these types of
changes. We also proposed an exception for increases in costs up
to one hundred dollars. In addition, we proposed to allow consumers to waive the 3-day period in situations of personal financial
emergencies.
We understand your concern about delayed closings, which was
also raised by numerous commenters. This is also a concern of the
Bureau. Many of the comments on this issue suggested modifications to the proposed exceptions or the addition of new exceptions.
We are reviewing these comments to determine the most appropriate way to provide meaningful consumer disclosure while, at the
same time, avoid unnecessary delays in closings.
Q.2. During your testimony to the Senate Banking Committee the
following statement was made: So the issue of indirect auto lending is one that, at this point, we address in a very general way
with . . . a legal analysis that leads to a legal conclusion. Its not
yet a factual conclusion about any particular instance, although
theres a lot to be heard about this area as you go around the country and listen to people, both lenders and borrowers both. Please
reconcile this remark with, and explain the specific basis for (to include providing any supporting data), the public statements made
by the CFPB in the fair lending guidance or the accompanying
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press release that the Bureau issued on March 21, 2013. If this
was simply a legal analysis, why was it released as a guidance and
for what reason would lender be compelled to begin complying immediately?
A.2. The legal analysis that the Bureau has undertaken, and that
I referenced in my testimony, has focused on the question of whether and under what circumstances indirect auto lenders are creditors under the Equal Credit Opportunity Act (ECOA) and on the
obligation that ECOA places on creditors to monitor the effect of
their lending policies on protected classes. The Bulletin that the
Bureau issued on March 21, 2013, contained the Bureaus legal
analysis and conclusions on those questions. The Bureau published
that Bulletin in order to provide transparency to indirect auto lenders with respect to the Bureaus perspective on these issues because that perspective will inform the examinations the Bureau
conducts and will provide the legal framework that the Bureau will
apply to the facts that the Bureau finds.
These questions about methodology and analysis are critical to
and proxies that the industry uses to self-monitor its lending activity for fair lending risk.
In a compliance bulletin published April 2012, the Bureau made
clear that it would adhere to the fair lending principles outlined in
Regulation B, the regulation originally promulgated by the Federal
Reserve Board under ECOA. In particular, under the legal doctrine
of disparate impact, a creditor may be responsible for a facially
neutral policy or practice that is applied equally, if that policy or
practice has, on a prohibited basis, a disproportionate adverse effect, unless the policy is justified by a legitimate business need
that cannot reasonably be achieved as well by means that are less
disparate in their impact.
There are multiple steps in assessing whether a facially neutral
policy or practice violates the law. The first step concerns whether
the policy or practice has a disparate impact on a prohibited basis
(i.e., disproportionately, adversely affects borrowers on the basis of
race, sex, national origin, etc.). However, even if a policy has a disparate impact, the policy does not violate the law if there is a legitimate business need for the policy that cannot reasonably be
achieved as well by an alternative that has a discriminatory impact. If, however, a creditor has a policy or practice that is not justified by a legitimate business need, or the need could reasonably
be met by an alternative with a less disparate impact, then the Bureau can pursue corrective action through the supervisory process
or through enforcement action.
The evaluation of whether a facially neutral policy violates
ECOA requires multiple steps and shifting burdens. Without applying all the requisite steps of the disparate impact analysis, the Bureau will not draw any conclusions about whether a facially neutral
policy with a disparate impact on protected classes violates ECOA,
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but the Bureau may note the existence of inadequately managed
fair lending risk.
Q.3. The guidance issued on March 21st of this year stated the following: The supervisory experience of the CFPB confirms that
some indirect auto lenders have policies that allow auto dealers to
mark up lender-established buy rates and that compensate dealers
for those markups in the form of reserve . . . . Because of the incentives these policies create, and the discretion they permit, there
is a significant risk that they will result in pricing disparities on
the basis of race, national origin, and potentially other prohibited
bases. Please explain in detail how indirect auto lender policies
that allow auto dealers to mark up lender-established buy rates
create incentives that result in a significant risk of disparate impact on a prohibited basis. Please provide any data, studies, or
other materials that resulted in this conclusion.
A.3. When a lender offers to pay higher compensation to a dealer
if the dealer procures a higher-priced contract from a consumer, an
incentive is creating to upcharge consumers. As a general matter,
discretion in pricing can increase fair lending risk, as discussed in
the Interagency Fair Lending Procedures, which have been adopted
by all the Federal financial supervisors, including the Bureau. Discretion that is not properly controlled has often been a source of
discriminatory disparities, both in auto lending and in other product markets like mortgage. Over the past decade, the Department
of Justice has settled a number of cases in which discretionary
pricing exercised by loan originators in wholesale transactions resulted in alleged disparities on the basis of race and ethnicity. In
addition, evidence submitted in many private lawsuits from the
last has revealed consistent disparities in markup that adversely
affected African American and Hispanic borrowers.
The March compliance bulletin provides guidance about compliance with the fair lending requirements of the Equal Credit Opportunity Act (ECOA) and its implementing regulation, Regulation B,
for indirect auto lenders that permit dealers to increase consumer
interest rates and that compensate dealers with a share of the increased interest revenues. The Bureau published the bulletin in
part to provide clarity for indirect auto lenders that may have been
operating under the incorrect assumption that they cannot be liable
under the ECOA for pricing disparities caused by markup and compensation policies.
Q.4. Mr. Cordray also stated to the Senate Banking Committee
that there is a possibility that the Bureau would write regulations involving disparate impact in indirect auto lending. Please
fully explain (i) what specific regulations the Bureau is considering
writing, (ii) what specific determinations the Bureau would have to
make before deciding to write such regulations, (iii) whether, and
to what extent, the Bureau would coordinate with the Board of
Governors of the Federal Reserve (FRB) and the Federal Trade
Commission (FTC) as part of this process, and (iv) the most likely
timetable for initiating this process.
A.4. The Bureau is not planning on writing specific regulations on
auto lending at this time. However, the Bureau is preserving its
option to use rulemaking as one of the regulatory tools to ensure
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that the market for auto lending provides fair, equitable, and nondiscriminatory access to credit for consumers.
Any decision by the Bureau to write regulations on disparate impact in indirect auto lending would depend on an evaluation of our
statutory authority and the Bureaus view on the adequacy of existing regulations or other regulatory tools available to the Bureau to
address risks to consumers arising from practices that may create
disparate impacts in indirect auto lending. The Bureau would also
consider the potential costs and benefits to, and potential impact
on, consumers and industry stakeholders that would be covered by
any potential regulations.
The Bureau is committed to working closely with the prudential
regulators and other Federal agencies, including the Board of Governors of the Federal Reserve (FRB) and the Federal Trade Commission (FTC), in conjunction with any decision to write auto lending regulations. With regard to auto lending in particular, the Bureaus commitment to coordination with other regulators stems
from a number of sources: (1) the Bureaus statutory obligation to
consult with prudential and other appropriate Federal regulators
in the process of its rulemakings; (2) the fact that other Federal
regulators, including the FRB and FTC, have significant regulatory
authority over auto lending; and (3) the Bureaus commitment to
adopt regulations that both protect consumer interests, including
access to credit, and preserve the ability of industry actors to pursue legitimate business objectives.
The Bureau is continuing to review the operations of indirect
auto lenders to ensure their compliance with fair lending and other
Federal consumer financial laws. The future timetable for any decision to begin developing regulations would depend on the results
of that review, our evaluation of all tools available to us to address
risks involving disparate impact in auto lending, and our assessment of market dynamics.
RESPONSES TO WRITTEN QUESTIONS OF SENATOR COBURN
Q.1. The list of contracts provided by the Consumer Financial Protection Bureau (CFPB) in response to Questions for the Record
(QFRs) from the March 12, 2013, nominations hearing included a
large number of professional services contracts, including for professional management and consulting services. What kinds of services are these contracted firms performing and does CFPB have
any processes in place to prevent duplication of functions between
different professional services contracts or interagency arrangements? What metrics does CFPB use to assess the value it obtains
from contracting with private firms and what is the frequency of
this evaluation process?
A.1. The Bureau does procure a variety of professional services and
management consulting support, including strategy formulation,
business initiative support, program/project management support,
performance management support and performance improvements,
contact center support, training, research, studies, and analyses.
Early in our brief history, these services were often needed to support the Bureaus stand-up operations. All Bureau contract awards
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above $3,000 are reported, along with a description of the service
or good, in the Federal Procurement Data System (FPDS). The
FPDS system is publicly available and any contract listing or description can be accessed through the use of the FPDS Web site
(www.FPDS.gov).
The Bureau mitigates any risk of duplication of functions between different professional services contracts or interagency arrangements through various methods. The Office of Procurement
maintains an award tracker or pipeline that is updated regularly
and monitored through a weekly briefing and evaluation with all
staff. The document provides a comprehensive listing of the Bureaus planned and budgeted purchases, from origination to award.
Managing the entire portfolio in this way allows for strategic
sourcing decisions where needed and helps avoid redundancy between any planned or awarded agreements. The Bureaus internal
control sheet, which is needed prior to any expenditure above
$3,000, provides additional risk mitigation. Before funds are released to the Office of Procurement, a control sheet is circulated
from the Office of the Chief Financial Officer that requires cross
functional approvals of the planned use of the funds. Investments
above $100,000 are approved in advance by the Senior Procurement Executive, Chief Financial Officer, Chief Operation Officer,
and Chief of Staff. Lastly, our Investment Review Board, chaired
by the Chief Financial Officer and comprised of senior agency staff,
reviews and approves planned investments above $500,000.
The value that the Bureau obtains from contracting with the
vendor community is described in the Contracting Officer Representatives (COR) Monthly Performance Report. Each contract is
assigned a COR at the time of award. CORs must take required
training for certification and attend a monthly roundtable hosted
by the Office of Procurement, which covers a variety of learning
initiatives and best practice discussions. Further, each COR is responsible for submitting a Performance Report for monitored contracts exceeding $150,000 to the Office of Procurement on a monthly basis. Each monthly report details the vendors performance
from the prior month and covers quality of service, cost control,
timeliness of performance, and business relations. The Office of
Procurement accumulates the individual reports and submits a
comprehensive vendor scorecard to agency leadership, and the Office acts promptly to address any problems that appear in the
monthly report. There is also a grading scale included in the scorecard that indicates change in performance from the previous
month.
Q.2. The Government Accountability Office (GAO) identified concerns during the creation of the Department of Homeland Security
(DHS) that an overreliance on contractors performing work that
are inherently Government functions created risks for Government
and taxpayer interests (GAO-08-142T). What steps is CFPB taking
to maintain visibility into the work that is being performed by private sector consultants and to ensure that consultants are not performing any work that should only be done by Federal employees?
What kind of controls and oversight procedures does CFPB have in
place for private contracting services that obtain sensitive information, such as private consumer credit data?
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A.2. The Bureau utilizes a Service Contract Code Worksheet in
order to maintain visibility into the work being performed by private sector consultants and to ensure consultants are not performing any work that should only be done by Federal employees.
The Worksheet is in response to the Office of Federal Procurement
Policys Policy Letter 11-01, which establishes requirements for review and management of service contracts over $25,000. The form
is a workforce balancing tool and also requires a service need to be
vetted through the Chief Human Capital Officer to ensure any
service request is not inherently governmental. Procurements can
only proceed if the form is approved by CHCO and the service is
not considered inherent to the Government.
Sensitive information is protected by the Bureau through specific
controls. The Bureau includes contract language covering data
rights usage for the development and production of any deliverable
submission as a result of Bureau funding. The data rights language
when utilized, allows the Bureau to govern access and distribution
of any delivered data. Furthermore, vendors that may receive sensitive data in the course of performing contract requirements must
sign a Non-Disclosure Agreement (NDA). The executed NDA does
not allow a vendor to divulge any sensitive, unclassified or confidential information to any third party without the Bureaus express approval.
Q.3. Data provided in response to QFRs in March shows that
CFPB is utilizing a number of contracts awarded by the Treasury,
including sole source contracts. GAO has identified interagency
contracting on its high risk list for many years due to problematic
incentives it creates, including avoidance of competitive processes,
conflicts of interest among participants in interagency contracts,
and lack of adequate oversight. Please provide the specific justification for each case of why CFPB is utilizing contracts awarded by
the Treasury. Among these, why have some of the interagency contracts been issued as sole source, rather than competed? How does
CFPB coordinate with Treasury to ensure that proper oversight of
interagency contracts is taking place? Is the CFPB paying fees to
Treasury, or any other agency, that is providing contracting assistance? If so, what are the fee rates and what is the total amount
of aggregate fees paid to each agency during FY2012 and FY2013?
A.3. During the stand-up of the Bureau as part of Treasury, the
Bureau was able to access and order services from existing Treasury vehicles when deemed appropriate. The decision to utilize certain Treasury contract agreements was considered efficient as the
service requirements already considered competition and were
awarded with fair and reasonable pricing. Such ordering lowered
opportunity cost and enabled crucial support of emergent needs as
the Bureau continued to stand up. Treasury agreements were utilized to order or provide for human capital support services, technology services, independent audit services, and administrative
support services. Ordered pricing was evaluated and determined
fair and reasonable prior to award. In addition to utilizing Treasury contracts, the Bureau has and continues to engage in an interagency agreement with Treasury Departmental Offices to leverage
printing and graphics, events planning, lease, and technology sup-
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399
port services. Most interagency agreements such as the agreement
with Treasury were placed under the authority of the Economy Act
per Federal Acquisition Regulation 17.502-2. When issued, interagency agreements are not subject to competition requirements as
the agreement is between two Government agencies and determined to be in the best interest of the Government as the services
cannot be obtained as conveniently or economically by contracting
direct with private sources. If the agreement results in the other
Government agency utilizing contract services, then any such
agreements are subject to the competition rules of the FAR or procurement rules of that particular agency.
Interagency contracts are jointly monitored by the participating
agencies in the interagency contracts. The Bureau monitors interagency contracts similarly to contracts directly with private
sources, ensuring services are provided within the contract terms
and conditions. The Bureau also utilizes the contracting assistance
of the Department of the Treasurys Bureau of the Public Debt Administrative Resource Center (BPDARC). The procurement services of BPDARC are defined in an interagency agreement. The
BPDARC staff serve as an extension of the Bureaus internal Procurement team and are therefore managed as such. The procurement services cost $771,394 in FY2012 and $1,119,048 in FY2013.
Q.4. For each contract or task order awarded on a sole source basis
during FY2012 and FY2013, please provide the written justification
from the contract file describing why the contract was awarded on
a sole source basis, as well as a summary of the statement of work
describing the purpose of the contract.
A.4. See attached listing of sole source contracts with justifications
included.
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Q.5. On March 21st, CFPB issued a guidance bulletin announcing
that it will treat indirect auto lenders as creditors subject to the
Equal Credit Opportunity Act (ECOA), specifically targeting dealer markup and compensation arrangements between dealers and
lenders that may result in discriminatory pricing. CFPBs usage of
disparate impact holds lenders liable for actions that have a discriminatory effect, even without discriminatory intent. Please provide a detailed methodology CFPB plans to utilize to analyze and
identify cases of disparate impact in the indirect auto lending sector.
A.5. These questions about methodology and analysis are critical to
and proxies that industry uses to self-monitor its lending activity
for fair lending risk.
In a compliance bulletin published April 2012, the Bureau made
clear that it would adhere to the fair lending principles outlined in
Regulation B, the regulation originally promulgated by the Federal
Reserve Board under ECOA. In particular, under the legal doctrine
of disparate impact, a creditor may be responsible for a facially
neutral policy or practice that is applied equally, if that policy or
practice has, on a prohibited basis, a disproportionate adverse effect, unless the policy is justified by a legitimate business need
that cannot reasonably be achieved as well by means that are less
disparate in their impact.
There are multiple steps in assessing whether a facially neutral
policy or practice violates the law. The first step concerns whether
the policy or practice has a disparate impact on a prohibited basis
(i.e., disproportionately, adversely affects borrowers on the basis of
race, sex, national origin, etc.). However, even if a policy has a disparate impact, the policy does not violate the law if there is a legitimate business need for the policy that cannot reasonably be
achieved as well by an alternative that has a discriminatory impact. If, however, a creditor has a policy or practice that is not justified by a legitimate business need, or the need could reasonably
be met by an alternative with a less disparate impact, then the Bureau can pursue corrective action through the supervisory process
or through enforcement action.
The evaluation of whether a facially neutral policy violates
ECOA requires multiple steps and shifting burdens. Without applying all the requisite steps of the disparate impact analysis, the Bureau will not draw any conclusions about whether a facially neutral
policy with a disparate impact on protected classes violates ECOA,
but the Bureau may note the existence of inadequately managed
fair lending risk.
Demographic information, such as race, sex, and ethnicity, are
generally not collected by nonmortgage lenders but are vital to assessing fair lending compliance. Thus, Federal regulatory and enforcement agencies have long used proxy methods in nonmortgage
data analyses. These methods are well accepted by economists and
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by regulators. Like other agencies, the Bureau also uses proxies for
demographic characteristics. We have made clear that we base our
proxies on publicly available data. For example, as a proxy for sex
we use data on first names published by the Social Security Administration. For race and ethnicity, we use both surname and geographical data published by the Census Bureau. Various proxy
techniques are publicly available in academic research, and we encourage indirect auto lenders to select a reasonable method and
begin to examine their data, if they have not done so already.
Q.6. In Assistant Director Busettes testimony during an April 26,
2012, hearing in front of the Subcommittee on Oversight of Government Management, and again in a letter submitted to GAO on July
3, 2012, references to a CFPB initiative titled the Financial Education Program Evaluation Project were made. According to the
testimony and letter, this initiative would use rigorous quantitative
methodologies to assess the effectiveness of existing Federal financial education programs. Does CFPB still plan to undertake and
complete an analysis of existing Federal financial literacy programs? What metrics does CFPB use to assess the effectiveness of
the agencys financial literacy activities? What steps has CFPB
taken to ensure its financial education programs do not overlap or
duplicate the multitude of existing financial education programs
identified by GAO?
A.6. The Bureau is committed to ensuring that its activities are informed by data and analytics. As part of that effort, the Bureaus
Office of Financial Education (OFE) has launched its initial Financial Education Program Evaluation Project. Using rigorous quantitative methodologies, this project will assess the effectiveness of
several existing financial education programs. We intend to use the
insights from this study to provide direction to practitioners about
how to design and support effective financial capability and money
confidence programs.
When the research is complete, we will understand whether
these programs are effective in imparting personal financial management knowledge and skills to program participants, and if so,
what elements account for this success. Our goal is to broadly
share the results with Federal Government agencies and other nonFederal providers of financial education so that they can integrate
the findings from this research into their offerings. At this time, we
do not anticipate undertaking an assessment of other Federal Government agencies financial education. However, we will facilitate
the sharing of programmatic best practices, evaluation methodologies, and common metrics that promote effective financial education among practitioners and other researchers.
We use a variety of metrics to assess the effectiveness of our activities and each activity may have a different metric. For example,
in the case of the Financial Education Program Evaluation project,
we measure effective performance by the quality and timeliness of
the projects interim and final deliverables. For our tools and publications, we measure public demand for the materials by, for instance, the number of downloads or fulfillment requests.
OFE is engaged in initiatives that advance financial education
opportunities for American families in a manner that leverages and
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407
complements existing Federal efforts. By meaningfully engaging
with other agencies, including Financial Literacy and Education
Commission (FLEC) partners, we work to delineate roles and responsibilities, to improve coordination, and avoid duplication while
working to fulfill our statutory mandate to educate and empower
consumers to make informed financial decisions. I serve as the
Vice-Chairman of the Financial Literacy and Education Commission. OFE staff meets regularly with the Department of the Treasury staff members in the Office of Financial Education and Financial Access to ensure coordination. As you are probably aware, the
GAO has recently indicated in its 2013 Annual Report: Actions
Needed to Reduce Fragmentation, Overlap, and Duplication and
Achieve Other Financial Benefits that all actions in the financial
literacy areas contained within the two previous reports were addressed.
The complex financial marketplace creates special challenges for
consumers and requires a range of strategies and approaches. We
are committed to thoughtfully focusing the talent of the Bureau on
ensuring that American families understand the choices available
to them as they manage their finances. We are equally committed
to continuing our work with Federal agency partners to leverage all
available resources, expertise, and opportunities for improving the
financial well-being of consumers.
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ADDITIONAL MATERIAL SUPPLIED
FOR THE
RECORD
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SEMI-ANNUAL REPORT OF THE CONSUMER FINANCIAL PROTECTION

BUREAU
409
Message from
Richard Cordray
Director of the CFPB
At the Consumer Financial PrGtection Bureau, we are the nation's first federal ageru:y whose sole
fOC\lS is protecting consumers in the financial marketplace. Weare dedicated 10 imprmi ng the
1i."es of e\'~ryday Americans.
Two founding principles that lie at the heart (If the American dream are equal opportunity and
the opportunily ((II" upward mooility. The consumer financial markets allow people to climb this
economic ladder, and 01.11' job at the Bureau is 1(1 hold that ladder steady.
This Semi-Annual Report reflects the Bureau's efJortsto dojust that. Througb e;w-handed and
re3sonableo\'crsight of the market, the Bureau is working to make the market fair, transparent,
and competitive, as the Dodd-frankAct directs us to do. Through our enforcement actions, we
have obtained about $425 million in refunds forconsumers who were wronged by credit card
companies.
We have established a number of tools to equip consumers ",ith the information they need tl)
make responsible financial decisioos. We h.weanswered nearlyl,ooo of consumers' JIl()I;t
frequently asked questions, and if you have more questions, you can ask us at
consumerfinance.gO\'1AskC FPB. Our Financial Ad Shopping Sheet and Financial Aid
Comparison Shopper ha\'e been helping students and their families better understand the
student loan process.
Coosumers deserve to be treated fairly and haw someone on thei r side when they are not. To
that end, the Bureau has strengthened our Officeof Consnmer Responseand since our doors
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SEIoIhIoIIIIU'I. REPOIlT OF THE CFPS. MAAO! 2013
410
opened in July 2011, we have received over 100,000 consumer complaints from people seeking
help on topics such as their m()rtgages, credit cards, bank products, student loans, and credit
repGrting.
Each day, we work to aocomplish the goal!; of rertrning consumers' trust in the marketplace and
ensuring that fi nancial products and r.ervices help consumers climb that eronomic ladder of
oppGrtunity. Any progress we are making is attributable to the hard work perfonned by our
team - people of the highest caliber who are dedicated to public service and protecting American
consumers.
We \ook forward to continuing to fulfill C01\gresss \ision of an agency dedicated to cultivating a
consumer financial marketplace based on responsible practices, sound inllO\'ation, and excellent
customer r.ervice.
Sincerely,
Richard Cordray
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Table of Contents
Message from Richard Cordray ................................................................................ 2
1. Executive Summary ........ ,,,.,, ............................................................................... 7
1.1
Consumer Challenges in Obtaining Financial Products and Services .... 8
1.2
Delivering for American Consumers and Leveling the Playing Field .... 9
1.3 Building a Great Institution .................................................................... 10

2. Consumer Challenges in Obtaining Financial Products and
Services .............................................................................................................. 12
2.1
Consumer Concerns ................................................................................ 12
2.2 Shopping Challenges .............................................................................. 36

2.3 Shopping Channels .................................................................................37
2-4 Product Complexity...............................................................................39
3. Delivering for American Consumers and Leveling the Playing
Field .................................................................................................................... 40
3.1
Resources for Consulners ...................................................................... 40
32 Outreach .................................................................................................. 47
33 Partnerships ...................................................... 49
4. Regulations and Guidance ................................................................................ 54
41
Implementing Statutory Protections ..................................................... 54
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412
4.2 Interpreting and Streamli ning Inherited Regulations; Facilitating

Compliance with New Regulations ........................................................ 58
5. Supervision ........................................................................................................ 60
5.1
Supervisory Activities ............................................................................ 60
5.2 Supervisory Guidance and Examination Procedures ............................ 62

5.3 Information Sharing With State Regulators .......................................... 64
5-4 Examiner Training and Commissioning ............................................... 64
55 Technology ............................................................................................. 65
6. Enforcement ....................................................................................................... 66
6.1 Conducti ng Investigations ..................................................................... 66

6.2 Public Supervisory and Enforcement Actions ....................................... 66
7. F.ir Lending ....................................................................................................... 70

7.1
Fair Lending Supervision........................................................................ 71
7.2 Fair Lending Enforcement ...................................................................... 72

7.3 Interagency Fair Lending Coordination .................................................72
8. Building. Gre.t Institution: Upd.te ................................................................. 74
8.1 Open Government ...................................................................................74

9. Budget. ................................................................................................................ 76
9.1 Howthe CFPB is Funded ........................................................................76
10. Diversity and Excellence ................................................................................... 83
10.1 Recruiting and Hiring ............................................................................ 83

10.2 Staff Education, Training and Engagement .......................................... 85
10.3 Diversity ................................................................................................. 86
Appendix A: .............................................................................................................. 91
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More about the CFPB ....................................................................................... 91

Appendix B: .............................................................................................................. 93
Statutory Reporting Requirements ................................................................ 93

Appendix c: .............................................................................................................. 95
Significant Rules, Orders, and Initiatives...................................................... 95

Appendix D: ............................................................................................................ 101
Actions Taken Regarding Rules, Orders, and Supervisory Actions with

Respect to Covered Persons which are not Credit Unions or Depository
Institutions .................................................................................................... 101
Appendix E: ............................................................................................................. 103
Reports .......................................................................................................... 103

Appendix F: ............................................................................................................. 104
Congressional Testimony...............................................................................104
Appendix G: ............................................................................................................ 106
Speeches ........................................................................................................106
Appendix H: ............................................................................................................ 109
Financial and Budget Reports .......................................................................109

Appendix I: .............................................................................................................. 111
CFPB Organizational Chart ............................................................................ 111

Appendix J: ............................................................................................................. 112
Defined Terms ................................................................................................ 112
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1. Executive Summary
The Consumer Financial Protection Bureau (CFPB or Bureau) is the nation's first federal agency
focused solely on consumer financial protection. 1 The Dodd-Frank Wall Street Refonn and
Consumer Protection Act (Dodd- Frank Act) created the CFPS to protect consumers offinancial
products and services and to encourage the fair, transparent and competitive operation of
consumer financial markets. The Bureau's mission is to make consumer financial markets work
for American consumers, honest businesses, and the economy as a whole.
The CFPB proudly presents its third Semi-Annual Report to the President and to Congress, in
fulfillment of its statutory responsibility and commitment to accountability and transparency.
This report updates the Congress and the American people on the Bureau's mission, activities,
accomplishments and publications since its last Semi-Annual Report 2, and additional
information required bythe Dodd-Frank Act. 3
I Previously, seven differen t federa l agencies were responsible for rulemaking, supervision, and enforcement relating
to consumer financial protection. "The agencies which previously administered statutes transferred to the Bureau are
the Federal Reserve Boord (and the Federal Reserve Banks), Department of HOIlSing and Urban Development (HUD),
Federal Deposit Insurance Corporation (FDIC), Federal Trade Commission (FTC), National Credit Union
Administration (NCUA), Office of the Comptroller of the Currency (ace), and Office of "Thrift Supervision (OTS).
2"The last Semi-Annual Report was published in July 2012 and may be viewed at
http://files.consumerflllance.gov/f/20120'Ufpb . Semi-AnnuaLReport.pdf.
3"The Semi-Annual Report primarily covers SLx-month increments beginning January 1st and July lSI. Certain
sections ohhis report cover the lime period belv.'een Janu31)' 1, 2012 and December 31, 2012. Appendix BprO\ides a
gnide to the Bureau's response to the reporting requirements of Section IOI6{C) of the Dodd-Frank Act.
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The Dodd-Frank Act requires the CFPB to:

Ensure that consumers have timely and understandable infonnation to make responsible
decisions about financial transactions;
Protect consumers from unfair, deceptive, or abusive acts and practices, and from
discrimination;
Identify and address outdated, unnecessary, or unduly burdensome regulations;
Promote fair competition by consistent enforcement of the consumer protection laws in
the Bureau's jurisdiction; and
Ensure that markets for consumer financial products and services operate transparently
and efficiently to facilitate access and innovation. 4
The Bureau has continued its efforts to listen and respond to consumers and industry, to
develop into a great institution worthy of the responsibility statutorily given to it by Congress,
and to be a resource for the American consumer.
1.1 Consumer Challenges in Obtaining

Financial Products and Services
In 2012, the Bureau sought input from consumers nationwide through different listening events,
roundtables and town halls, and from our website, consumerfinance.gov, We seek to learn about
their experiences with financial products and services, and collecting consumer input is an
important step toward understanding consumer challenges in obtaining financial products and
services in our troubling economic times, Consumer input is important for numerous reasons,
including development of a research and data-driven agenda and various tools designed to help
consumers of the financial services market obtain the products and services they need. We also
desire to help the providers of those products and services comply with applicable regulations
and keep the playing field fair for all participants.
The Bureau has also continued to improve and expand the capabilities of its Office of Consumer
Response to receive, process, and facilitate responses to consumer complaints, as well as
4See Dodd-Frank Act, Pub. L. No. 111-203, Sec. I021(b).
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establish a Consumer Complaint Database. The CFPBcontinually gathers data and information
about consumers' behaviors, choices and experiences when they shop for financial products and
how the market, market participants, and sales practices may influence the decisions that
consumers make.
1.2 Delivering for American Consumers

and Leveling the Playing Field
The CFPB continued to both develop and expand as a resource for consumers in 2012. For
example, the CFPB's Consumer Education and Engagement Division developed and
implemented initiatives to educate and empower consumers to make informed financial
decisions. Its information-gathering efforu, educational tools, and reports include programs
directed toward particular populations, such as service members, older Americans, and
students. The Division OfSUpelVision, Enforcement, and Fair Lending focused its efforu in 2012
on ensuring compliance with federal consumer financial laws and holding fina ncial institutions
accountable for their violations of those laws. The Research, Markets and Regulations Division
focused its efforts on promoting markets in which consumers can shop effectively for financial
products and selVices and finalizing a number of regulations implementing changes made by the
Dodd-Frank Act to the laws governing various aspects of the mortgage market, including the
origination and servicing of mortgages. While the various divisions of the Bureau play different
roles in carrying out the Bureau's mission, they all work together to protect and educate
consumers, keep the playing field fair for participants, and fulfill our statutory obligations under
the Dodd-Frank Act.
In 2012, the Bureau also:
Engaged in extensive outreach to consumers and industry throughout the count!)';
Established advisory bodies, and initiated and developed partnerships with federal
agencies, state financial regulatory entities, and state attorneys general;
Implemented statutory protections for consumers who use consumer financial products
and services, and continued the process of streamlining regulations that the CFPB
inherited from other fede ral regulatory agencies; and
Launched programs for supervising large banks, non-banks, and companies that provide
consumer financial products and services, and investigated potential violations of
consumer financial laws under the Bureau's jurisdiction.
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1.3 Building a Great Institution

Many of these effort!; have taken place during the Bureau's first full yea r as an independent
regula!!)!)' agency. As of December '5, 2012, the CFPB learn consisted of 1,073 employees
lI'()fking tocarryout the Bureau's missioo. lt has IIUrl;ed to build a human and physical
infl1lstructure that promCltes - and \1;11 continue to promote - trnnsparency, accountabil ity,
fairness, and service tothepublic. That includes:
Demonstrating a strong commitment to openness and utilizing the Bureau's website \()
share inform ation (In its operations;
Recruiting highly qualified personnel;
Pro\iding training and enga&ement opportunities for eHe staff to imp['()\l! skills,
increase knowledge, and maintain excellence; and
Promoting dil'ersity in the CFPB's workforce and among its contractors, including
through the Bureau's Officeof Minoritya nd Women Inclusion.
CFPB "",pl<>yml at In All Hands )Ieetq in Allguot 1Ol2
The CFPB is proud of the accomp~shments it achie>.ro. in 2012, but this marks only the
beginni ng of the Bureau's work on behalf of consumers and providers of financi1ll prodllCts and
services. In 2013, theCF PB's efforts t() makecolISumer financi1ll marketswOIk better \lill
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continue to expand. We invite you to visit the CFPB's website at consumerfinance.gov for
updates on our work over the coming months.
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419
2. Consumer Challenges in
Obtaining Financial Products
and Services
The challenges consumers face in obtaining financial products and sClVices are a driving force
behind the eFPS's efforts to make consumer financial markets work better. Listening and
responding to consumers are integral components of our mission, and the Bureau provides
numerous ways for consumers to make their voices heard.
2.1 Consumer Concerns

Financial markets are rooted in the daily lives and the financial and credit needs of individual
Americans. Consumer financial products and sClVices, when understood and appropriately
used, can bring broad benefits to consumers. Savings accounts are a first step to help people
pursue their dreams, and checking accounts facilitate everyday transactions. Mortgages help
people buy homes and pay for them over time. Credit cards give people convenient access to
money when needed. Student loans allow people who lack means but have talent and ambition
to pursue their deepest aspirations.
Over the past year, consumers have shared with the CFPBtheir experiences - positive and
negative - with financial products and services. Consumers have the opportunity to provide the
CFPB with such feedback through a variety of forums, including, among others, the ''Tell Your
Story~ feature on
the CFPB's website, roundtables, town halls, and field hearings. This feedback
is critical to our efforts to understand the challenges consumers face in obtaining the financial
products and services they need.
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420
The stories consumers have shared with the Bureau through "Tell Your Story" cover a wide
range of financial products and services, and provide snapshots of consumers' day-t(}-day
experiences in the financial marketplace, Consumers' stories are reviewed by CFPB staff and
further the Bureau's understanding of current issues in the financial marketplace. They also
supplement what we learn from listening to consumer complaints. 5 For example, consumers'
stories about student loans echo the issues raised in the CFPB Student Loan Ombudsman's
Annual Report about student loan complaints, The stories reflect consumers' fmstrations with
loan origination and repayment, and often describe how these challenges have affected their
day-to-day lives, as well as their long-term plans.
Consumers have expressed how their lives have been negatively impacted by their student loan
obligations. For example, some consumers have reported:
Experiencing difficulty balancing paying for basic necessities (housing, food,
transportation, healthcare) while having to repay student loan debt;
Amassing credit card debt to cover shortfalls due to having to repay shldent loan debt;
Delaying family planning (marriage, children) because of their debt burden; and
Being fearful that their debt burden will prevent them from owning a home, saving for
their children's education, and/or saving for retirement.
Stories illustrate that the lives of borrowers' family members have been adversely affected as
well:
Parents and/or grandparents who cosigned for borrowers unable to repay their loans are
now faced with having to repay these loans;
Parents and/or grandparents who borrowed money to help their children and/or
grandchildren pay for school are unable to repay the loans due to lost income; and
Family members are harassed by debt collectors collecting on student loans, even if they
did not cosign.
In addition to "Tell Your Story," consumers have opportunities to voice concerns and share their
experiences in person, Consumers and advocates have participated in large Bureau-sponsored
5Consumer complaints are submissions that express dissa tisfaction lIith, or communicate suspicion of wrongful
conduct by, an identiftable entity related to a consumer's personal a~perience with a financial product or ser.ice.
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public events in Detroit, MI, st. Louis, MO, Seattle, WA, and Mountain View, CA6, including
town halls, field hearings and public meetings, focused on particular consumer finance issues.
These events have drawn hundreds of participants, many of whom have shared their personal
experiences with credit reporting, debt collection, and other consumer financial issues.
The CFPB's Office of Community Affairs (OCA) has also hosted roundtable conversations with
leaders of consumer, civil rights, community, housing, faith, student, women, and other
organizations. The roundtables have provided opportunities for stakeholders to meet with
Director Cordray and other key Bureau staff to share their ground-level perspectives on key
consumer finance issues that affect their communities.
Collecting, investigating, and responding to consumer complaints are integral parts of the
eFPE's work, as Congress set forth in the Dodd-Frank Act. 7 The Office of Consumer Response
hears directly from consumers about the challenges they face in the marketplace, brings their
concerns to the attention of companies, and assists in addressing thei r complaints.
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7See Dodd-Frank Act, Pub. L No. 111-203, Sa:. 1021(CX2).
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422
The CFPB began Consumer Response operations on July 21,2011, by accepting consumer
complaints about credit cards. Consumer Response now accepts complaints related to bank
accounts and services, private student loans, mortgages, other consumer loans, and most
recently, on October 22, 2012, it began handling credit reporting complaints. The CFPB
continues to work toward expanding its complaint handling capacity to include other products
and services, such as money transfers, payday loans, and debt collection. Consumers may also
contact the CFPB with questions about other products and services. The Bureau answers these
questions and refers consumers to other regulators or additional resources as appropriate.
Consumer Complaint Database

Thi.llXlltainsdata!r(m the t(RI$Umereredit eard complaints reeeivtd bytheO:nsumer Financial!'n)tecti(Jl Rurean. We dOl\(t verify
the aceuraeyda11 /aetsal1eged in Ihese eomplainl!, but we dotakl! Slep;SlDtoofinn acommercial relatioosbip between thet(RI$Umer
and the identified eompany.
Cunplaintsue lisIed after tbecompanYrespa:ldsorafterthey have had the ccmplaintror 15ca1endardays, whiche\'erccmes first.
Cunplainlscan be remCMd iftbeyd(Jl' meet all dthe paley 5btements publicati(Jl criteria. Data isrefreshed daily.
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co nsumerfinance.gov / complaintdatabase
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423
Information about consumer credit card complaints is available to the public, through the
CFPB's public Consumer Complaint Database, launched on June 19, 2012,8 Initially populated
with credit card complaints received by the CFPB, the database was expanded in October 2012
to include consumer credit card complaints dating back to December 1, 2011. A complaint is
listed in the database when the company responds to the complaint confirming a commercial
relationship with the consumer, or after the company has had the complaint for 15 days,
whichever comes first. Complaints can be removed if they do not meet all of the publication
criteria.
The database is live, updates daily, and contains certain individual complaint~ l evel data
collected by the CFPB, including the type of complaint, the date of submission, the consumer's
zip code, and the company that the complaint concerns. The database also includes information
about the actions taken by a company in response to a complaint - whether the company's
response was timely, how the company responded, and whether the consumer disputed the
company's response. The database does not include confidential information about consumers'
identities. Web~based and user-friendly features of the database include the ability to filter data
based on specific search criteria, aggregate data in various ways, such as by complaint type,
company, zip code, date, or any combination of available variables, and download data.
Information from the database has been shared and evaluated on social media and using other
new applications.
In the summer of 2012, the CFPB asked for public comment on adding complaints about other
consumer financial products and services under its authority to the Consumer Complaint
Database and received a wide range of comments from interested stakeholders.9 The CFPB
continues to evaluate, among other things, the release of consumer narratives, the potential for
normalization of data to make comparisons easier, and the expansion of functionality to
improve user experience.
8 In December 2011, the CFPBasked the puh/ic to comment on a proposed policy of making some credit card
complaint data publicly available. Afterconsidering those comments, the CFPBfina lized its policy for disclosing some
of the data through its Consumer Complaint Database (Policy Statement). See Disclosure of Certain Credit Card
Complaint Data, 77 Fed. Reg. 37,558 (June 22, 2012).
9 In Ju ne 2012, the CFPBasked the public to comment on a proposed policy of duplicating the data disclosure
practices described in the Policy Statement for consumer complaints about other consumer financial products and
services ....ithin the Bureau'sjurisdiction. 77 FR37616 (Ju ne 22, 2012).
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2.1.1
How the CFPB Handles Complaints
In keeping ....ith the CFPB's statutory re<lponsibi~tyand its commitment tGaccountabmty, the
fl)UO\\ln& pa&es pfO'oide an overview of the handling and analysis of complaints receil-ed by
Consumer ResponsefromJanuary I, 2012 through December31, 2012.
Consumer Responsescreensall complaints submitted hYC()Ilsumer.;; based on sen~ral criteria,
includ ing whether the complaint falls lIithin the CF PB's primary enforcement authority,
whether the complaint is complete, and whether the complaim is duplicative of a pri()l"
submission bylhe same consumer. Screened complaints are forwarded ,ia a secure web portal
to the appropriate company.l0 The company re\iews the inf()ffllation, commu ni cates with the
consumer as needed,and determines what action to take in response. Then, the company
repClrtS back to the consumer and the CFPB ,;a the secure company portal", and the Bureau
invites the oonsumer to review the response and provide feedback. Consumer Response w.iews
the feedback consumers provide about oompany responses, using this infonnation along with
other information such as the timeliness (If the C1)Illpany's response, 11 f(lr example, to help
prioritize oomplaints for invl!stigation. Consumers who hall! submitted complaints to the
Bureau through Consumer Response can log (Into the secure "ronsumer portal" a'':Iilable on the
eFPB's website, or call a toll-free number. 10 re<:enl! status updates, provide additional
information. and rel'iew responses prolided to the conswner by the oompany.
Throughout this process, subject-matter e:'Iperts help monitor certain complainlll. For e:'Iample,
the Office of Servicemember Affairs coordi nates on rompiainlll filed by sen.icemembers or their
spouses and dependents.
10 H parliOlllar """plli.l d... noI in,...I1... prndud or madet lb.l " "i!hin l~. Bureau', jurisdidion. or &..1"
"UTtntly btinghl.dled by It:. Bu .... u.
~ refm it to ft.. appropriate rtglllolor.
Con""""
11 ll-.e CFPB tequesl, &..1 OOI:lpat.~ respot.d 10 oor:>p1oir.1S will-.in 15 r.alet,dardays. [f. com)'lllir:l car.noI be cbed
within 15 Wet,dar days. tOr.'lp8oy mayit.dicate &..1ii, work 00 lheW':lJllainl i, "!n progress- tr.d p""';(\e. final
"'"J'OU" wi&.in 60 OIludordays.
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Consumer Response continually strive.<; to improve data quality and protect sensitive
information, while increasingly making data about the complaints the CFPB receives available
through reports toCongre.<;s and the public, and by sharing certain data with the public through
the Consumer Complaint Database.
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426
2.1.2 Complaints Received by the CFPB

BetweenJanuary 1,20]2 and December 31, 2012, the CFPB received approximateiY91,oOO
consumer compiaints. 12
FIGURE 1: CONSUMER COMPLAINTS BY PRODUCT
1%
4%
C,ed' "'port;'9
Consumer loan
Student loan
- 17%
Bank
account
and service
The Dodd-Frank Act created the Office of Servicemember Affairs at CFr Bto address the specific
challenges faced by servicemembers, veterans, and their families (collectively

"servicemembers~).
It monitors complaints from servicemembers in conjunction with Consumer
Response. Behveen January 1,2012 and December 31, 2012, approximately 3,500 complaints
were submitted by servicemembers.
12 This analysis excludes multiple complaints submitted by a giW!D consumer on the same issue and whistleblower
tips. All data are current as of January 1, 2013. Since laullchillg CollSumer Respollse operatiolls 011 July 21, 2011, the
CFPB has received approo:imately 104,000 consumer complaints.
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427
FIGURE2: SERVICEMEMBER CQMPLAJNTS BY PRODUCT
5%
Student loan
- 15%
Bank
account
and service
Approximately 46% of all consumer complaints were submitted through the eFPS's website and
9% via telephone calls. Referrals accounted for 34% of all complaints received, with the
remainder submitted by mail, email, and fax.
The tables and figures presented below show complaints by type, actions taken, company
responses, and consumers' feedback about company responses. 13
\3 Percentages may not sum to 100% due to rounding.
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428
CONSUMERS ' CREDIT CARD COMPLAINTS
Table 1 shows the most common types of credit card complaints that the CFPB has received as
reported by consumers. 67% of the approximately 18,600 credit card complaints fell into these
10 categories.
TABLE 1: MOST COMMON CREDIT CARD COMPLAINTS REPORTED BY CONSUMERS

Complaint
14%
Billing disputes
Annual Percentage Rate (APR) or interest rate
Credit reporting
8%
Ident~y
7%
theftlFraudlEmbezzlemenl
Closing/Cancelling account
6%
Collection practices
5%
Other
5%
Late fee
4%
Credit card protection/Debt protection
4%
Collection dett dispute
4%
Credit Card CoJl1)laints in Top 10 Types
67%
As the table illustrates, billing disputes are the most COIDIDon type of credit card complaint.
Some consumers are confused and fmstrated bythe process and by their limited ability to
challenge inaccuracies on their monthly credit card billing statements. For example, some
consumers realize only after their claim has been denied that they needed to notify their credit
card companies within 60 days of any billing errors. In other cases, consumers are not aware
that companies typically do not stop a merchant charge once the cardholder has authorized it, or
do not override a merchant's "no-return policy." Other common types of credit card complaints
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429
relate to annual percentage rates (APRs) or interest rates, credit reporting, and identity theft,
fraud, or embezzlement.
The CFPBgenerally has relied on the consumer's characterization of his or her complaint to
identify its nature for analytical purposes. However, the CFPB's experience to date suggests that
consumers may have differing interpretations of what these categories mean. For example, one
consumer might choose to categorize a problem as a billing dispute, while another might
identify the same issue as a concern with a provider's setting or changing of an interest rate. To
improve our reporting on the data we receive, the Bureau is evaluating the use of these
categories by col15umers to date and developing a simplified identification scheme to promote
more consistent categorization of complaints.
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430
CONSUMERS ' MORTGAGE COMPLAINTS
Figure 3 shows the types of mortgage complaints reported by consumers for the approximately
45,200 mortgage complaints the CFPBhas received.
FIGURE 3: TYPES OF MORTGAGE COMPlAINTS REPORTED BY CONSUMERS
Complamt
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57%
Making .ooyments (Loan servicing, payments, escrow axoonts)
25%
Applying for the loan (Applicatial, originator, mortgage broker)
8%
Signif'9 the agreement (Settlement process and costs)
4%
other
4%
Receiving a credit offer (Credit decisioollJrderwriting)
2%
Total Mortgage COfl'1)laints
100%
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Problems when you are unable to pay (Loan mocJjfica~on, coIiECtial, fae::losure)
431
The most common type of mortgage complaint concerns problems consumers face when they
are unable to make payments, such as loan modifications, collections, or foreclosures.
Consumers who have submitted these complaints generally appear to be driven by a desire to
seek agreement with their companies on foreclosure alternatives. These complaints indicate that
consumer confusion persists around the process and requirements for obtaining loan
modification.s and refinancing, especially regarding document submission timeframes, payment
trial periods, allocation of payments, treatment of income in eligibility ca\culation.s, and credit
bureau reporting during the evaluation period. The shelf life of documents provided as part of
the loan modification process is of particular concern to consumers. Although con.sumers must
provide documents within short time periods and income documentation generally remains
valid for up to 60 days, lengthy evaluation periods can result in consumers having to resubmit
documentation - sometimes more than once, contributing to consumer fatigue and frustration
with these processes.
Other common types of mortgage complaints address issues related to making payments, such
as loan seIVicing, payments, or escrow accounts. For example, consumers express confusion as
to whether making timely trial period payments will guarantee placement into a permanent
modification. Issues related to applying for the loan, such as the application, the originator, or
the mortgage broker, are also among the most common types of mortgage complaints.
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432
CONSUMERS ' BANK ACCOUNT AND SER VICE COMPLAINTS
Figure 4 shows the types of bank account and service complaints, such as complaints about
checking and savings accounts, re{Xlrted by consumers for the approximately 15,700 complaints
received bythe CFPB.
FIGURE 4: TYPES OF BANK ACCOUNT AND SERVICE COMPLAINTS REPORTED BY CONSUMERS
6%
Using a debit or
ATM card
I
10%
Sending or
receiving
payments
16%
Problems
caused by
low funds
Complaint
Account opening, closing, or management (Confusing
fees, closure, interest, statements, joint occounts)
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denial, disclosure,
41%
OeJXlS~S aoo withdrawals (Availability r:i dep:)sits, withdrClWal proo/ems and

penalties, unalAtmzaJ transactions, chfk Cashing, payroll deposit prcb/ems, lost
ex missing fuOOs, traflSaGtion OOIds)
27%
Problems caused by my funds being low (Overdraft fees, late fees, tounced checks,
crOOit reporting)
16%
Making or receiving payments, sending money to others (PrOOlems with payments

by cfler;k, card, ph<:ne (y online, unauthct"ized or fraudulent tratlsechons,
mooeYNl/lfe transfers)
10%
Using a debit or ATM ca rd (Disputed transection, unauthxized card use, ArM ((

debit card fees, ArM problems)
6%
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marke~ng,
433
100%
Total Bank Account and Service Complaints
As the table iIIustrat'.'i, the most common type of bank account and service complaint relat'.'i to
opening, closing, or managing the account. These complaints addr'.'is issues such as confusing
marketing, denial, fees, statements, and joint accounts. Other common complaints relate to
deposit and withdrawal issues, such as transaction holds and unauthorized transactioll'l, and
problems caused by the consumer's funds being low, including bounced checks, overdraft and
late fees, and credit reporting. Many consumers remain frustrated ....1th overdraft fees and the
wide discretion companies have to assess these and other fees, so long as the fees are outlined in
account agreements. Similarly, some consumers express frustration when some companies
process larger withdrawal transactions before smaller ones, which can generate more overdraft
fees.
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434
CONSUMERS ' STUDENT LOAN COMPLAINTS
Figure 5 shows the types of student loan complaints reported by consumers for the
approximately 3,900 student loan complaints received by the CFPB.
FIGURE 5: TYPES OF STUDENT LOAN COMPLAINTS REPORTED BY CONSUMERS
5%
Getting a loan
I
Complaint
Repaying your loan (Fees, bi/lir)J, ooferment, fabeararx:e, fraud, credit reportifYJ)
64%
Problems when you are unable to pay (Default, debt co/Ja;tion, bankruptcy)
31%
Getting a loan (Confusir) terms, rates, denial. CoofU5iIYJ advertisir)J or

marketifYJ, sales tactics or pressure, financial aid services, recruiting)
5%
Total Student Loan Complaints
100%
The most common type of student loan complaint relates to repaying the loan, such as fees,
billing, defennent, forbearance, fraud , and credit reporting. Consumers struggle with the limited
payment deferment options permitted in their loan agreements, especially when they have not
found employment by the time they must begin repaying their loans, and because deferments
often are limited to six months. Another common type of complaint addresses problems
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435
consumers confront when they are unable to pay, such as issues related to default, debt
collection, and bankmptcy.
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436
CONSUMERS ' CONSUMER LOAN COMPLAINTS
Figure 6 shows the types of consumer loan complaints, sllch as complaints about installment
loans, vehicle loans and leases, and personal lines of credit, reported by consumers for the
approximately3,200 consumer loan complaints received by the CFPB.
FIGURE6: TYPES OF CONSUMER LOAN COMPLAINTS REPORTED BY CONSUMERS
9%
Shopping for the loan
I
- 18%
Taking out
the foan
Complaint
Managing the loan, lease, or line of credit (Billing, late fees, damage or loss, insurance
(GAP, credit, etc) , credit repating, priva:y)
49%
Problems when you are unable to pay (Debt collection, repossession, set-df fran bank
axount, deficierr:y, bankruptcy, default)
24%
Taking out the loan or lease f Account terms and changes (Term changes (mid-deal
cha(1Jes. cha(yJes after cloSirfJ, rates. fees, etc.), required ackJ-on procJucts, tracJe.in
paycif, fraud)
18%
Shopping for a loan, lease, or line of credit (Sales tactics or pressure, cffdit denial,
ccnfusing advertisirq ex marketirq)
Total Consumef Loan Complaints
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100%
437
The table illustrates that the most common type of consumer loan complaint pertains to
managing the loan, lease, or line of credit. Another common type of complaint addresses
problems consumers have when they are unable to pay, including issues related to debt
collection, bankruptcy, and default.
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438
CONSUMERS ' CREDIT REPORTING COMPLAINTS
Figure 7 shows the types of credit reporting complaints reported by consumers for the
approximately 3,300 credit reporting complaints the CFPB has received. ]4
FIGURE7: TYPES OF CREDIT REPORTING COMPLAINTS REPORTED BY CONSUMERS
2'1\
00"
3'1\
I Credit monitoring or identity protection
II
r--- 3'1\
Improper use of credit report
- -7'1\
Unable to obtain
Complaint
Incorrect information on credit report (Information is 001 mine, Account terms, Account status,
Perswai informatictl, Public rocord, Reinsetted previously deJeted informatiCtl)
73%
Credit re~rtirg company's investigation (Investigation t()()/{ too /ooJ, Did oot get pr~ notice
d investigaticrl status or results, Did net receive ada:!uate help CHef the phcre, Problem with
statement of dispute)
Unable to get my credit report or credit score (PrcbJem geltirtg free annual repro, Problem
geffirYJ report or credit seae)
7%
14ConSllmer Response began handling credit reporting rompiainlson October 22, 2012.
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439
Improper use of my credit rel>'Jrting (Repat improperly sharEd by credit repatirq canpany,
ReceivEd marketing cifers after oplifYJ out, Report provided to employer witfk:Jut written
authcrization)
3%
Credit monitoring or identity protection services (Problem cance/lifYJ or closing account, 8illifYJ
dispute, ReceivilY,/ unwantEd marketing or adverlisifYJ, Account or product terms and
changes, Prcblem with fraud a/erls)
3%
Other
2%
Total Credit Reporting Complaints
100010
This table illustrates that the most common type of credit reporting complaint is about incorrect
information appearing on the consumer's credit report, such as information that is not the
consumer's, incorrect account status, and incorrect personal information. Another common type
of complaint is about issues with credit reporting companies' investigations of information
disputed by consumers.
HOW COMPANIES RESPOND TO CONSUMER COMPLAINTS
Approximately 75.400 (or 83%) of all complaints received behveen January 1, 201 2 and
December 31, 2012 were sent by Consumer Response to companies for reviewand response.IS
Table 2 shows how companies responded to these complaints during this time period.
Company responses include descriptions of steps taken or that will betaken, communications
received from the consumer, any follow-up actions or planned follow-up actions, and
categorization of the resJXlnse. Based on industry comments received about disclosure of credit
card complaint data, beginning June 1, 2012, response category options included "closed with
monetary relief,~ ~closed with non-monetary relief," "closed with explanation," "closed," "in
progress," and other administrative options. Monetary relief is defined as objective, measurable,
and verifiable monetary relief to the consumer as a direct result of the steps taken or that will be
taken in response to the complaint. "Closed with non-monetary relief indicates that the steps
taken by the company in response to the complaint did not result in monetary relief to the
IS The remaining complaints haw been referred to other regulatory agencies (11%), found to be incomplete (3%), or
are pending with the consumer or the CFl'B (1% and 3%, respectiwly).
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440
consumer that is objective, measurable, and verifiable, but may have addressed some or all of
the consumer's complaint involving non-monetary requests. Non-monetary relief is defined as
other objective and verifiable relief to the consumer as a direct result of the steps taken or that
will be taken in response to the complaint. "Closed with explanation" indicates that the steps
taken by the company in response to the complaint included an explanation that was tailored to
the individual consumer's complaint. For example, this category would be used if the
explanation substantively meets the consumer's desired resolution or explains why no further
action will be taken. Tlosed ~ indicates that the company closed the complaint without relief monetary or non-monetary - or explanation Consumers are given the option to revie\v and
dispute all company closure responses.
TABLE 2:
HOW COMPANIES HAVE RESPONDED TO CONSUMER COMPLAINTS
All
Credit card Mortgage
Bank account
and service
I6
student Consumer Credit

loa n
loan
reporting
75,400 15,700
39,500
13,000
2,900
2,100
2,000
Company reported
closed with
explanation
65%
56%
72%
57%
71%
66%
59%
Company relXlrted
closed with
monetary relief
15%
29%
5%
28%
7%
12%
1%
Company reported
closed with non
monetary relief
9%
8%
10%
5%
11%
9%
16%
Company
reviewing
7%
4%
8%
5%
8%
8%
23%
16 While companies' responses under previous categorizations were maintained, for operational and reporting
purposes, responses categorized as ~fun resolution provided," "partial resolution provided," and "closed with relief'
are considered a subset of "dosed with monetary relief," and responses calegorized as "no resolution provided" and
"d osed wit bout relief' are calegorized as "dosed with explanation." 'Closed wilb non-monetary relief' and "dosed"
reflect only those responses provided by companies after June I, 20 12.
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441
Company provided
administrative
3%
response
2%
3%
3%
2%
2%
1%
Company reported
closed (without
2%
relief or
explanation)
1%
2%
3%
1%
4%
0%
100%
100%
100%
100%
Companies have responded to approximately 95% of complaints 17 sent to them and report
having closed 90% of the complaints sent to them. Table 2 shows how companies have
responded.
Beginning December 1, 2011, companies had the option to report an amount of monetary relief,
where applicable. In 2012, companies have provided relief amounts in response to more than
9,300 complaints. The median amount of relief reported by companies was $145; however,
company reports of relief amounts and medians vary byproduct. For the approximately 4,100
credit card complaints where companies provided a relief amount, the median amount of relief
reported was approximately $123. For the approximately 1,400 mortgage complaints where
companies provided a relief amount, the median amount of relief reported was approximately
$413. For the more than 3,300 bank account and service complaints where companies provided
a relief amount, the median amount of relief reported was approximately $105. For the
approximately 200 student loan complaints where companies provided a relief amount, the
median amount of relief reported was approximately $1,307. And fo r the approximately 200
consumer loan complaints where companies provided a relief amount, the median amount of
relief reported was approximately $174.
CONSUMERS ' RE VIE WS OF COMPANIES ' RESPONSES
Once the company responds, the CFPBprovides the company's response to the consumer for
review. Where the company responds "closed with monetary relief,n "closed with non-monetary
17 ApproximalelY71,Jooof7S,400.
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442
relief," "closed with explanation," or "closed," consumers are given the option to provide
feedback on the company's ra<iponse. Table 3 shows how consumers responded to the
approximately 68,000 complaints where they were given the option to provide feedback.
Consumers are asked to notify the CFPB within 30 days if they want to provide feedback by
disputing a company's ra<iponse. Approximately 61% of such consumers did not dispute the
ra<iponses provided, while approximately 22% of consumers did dispute the response provided.
The ra<it were pending with consumers at the end of this period.
TABLE 3:
Credit
card
Bank account student

Mortgage andseNice
loan
Consumer did not

dispute com~ny's
response
61%
67%
59%
64%
67%
57%
21%
Consumer disputed
com~ny's response
22%
20%
24%
21%
19%
24%
20%
Pending consumer
review of com~ny's
response
17%
14%
17%
16%
14%
19%
59%
Total
Complaints
100% 100%
100%
100%
100%
100%
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Consumer Credit
loan
reporting
"I
35
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CONSUMER FEEDBACK ABOUT COMPANY RESPONSES
443
CONSUMER RESPONSE IN VESTIGATION AND ANALYSIS
After requesting that companie.<; respond to complaints sent to them fo r response and giving
consumers the opportunity to review and provide feedback on company responses, Consumer
Response prioritizes complaints for investigation based on a review of the complaint, the
company's response, and the consumer's feedback. Consumer Response seeks to determine why
a company failed to provide a timely response (if applicable) and whether the consumer's
feedback of the company's response (if applicable) justifies additional review of the company's
minimum required actions under the consumer financial protection laws within the CFPB's
authority. In the course of an investigation, Consumer Response may ask companies and
consumers for additional information, and once an investigation is completed, Consumer
Response sends the consumer a summa I)'. In some cases, Consumer Response has referred
complaints to colleagues in the CFPB's Division of Supervision, Enforcement, and Fair Lending
and Equal Opportunityfor further action.
Listening to consumers and reviewing and analyzing their complaints is an integral part of the
CFPB's work in understanding issues in the financial marketplace, and in helping the market
work better for consumers. The information shared by consumers and companies throughout
the complaint process informs the Bureau about business practices that may pose risks to
consumers and helps the Bureau in its work to supervise companies, enforce federal consumer
financial laws, and write better rules and regulations.
2.2 Shopping Challenges

The challenges that consumers face in the marketplace highlight the importance of a tenet which
is central to the CFPB's mission - promoting markets in which consumers can shop effectively
for financial products and seIVices. When the costs, risks, and other key features of financial
products are transparent and understandable, consumers are better able to compare products
and choose the best one for them. This discussion presents preliminary obseIVations about
opportunities and challenges that consumers face when shopping for short term credit needs.
2.2.1 Small Dollar Lending

Many American households face an unexpected expense or simply find that their expenses
regularly outstrip their income, Low-to moderate-income households may use credit options
such as payday loans, pawn loans, or consumer finance installment loans to deal with a financial
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shortfall. Other strategies may include cutting back on expenses, delaying a bill payment,
tapping savings, or getting help from friends, family, or an employer. Individual consumers may
consider a range of products and strategies for this type of need. For example, several surveys of
payday loan borrowers found that a significant share of respondents considered other options,
either as an alternative to obtaining a payday loan or after some length of payday loan use,
including borrowing from their bank or credit union, taking a loan from a consumer finance
company, using a credit card, or getting assistance from a friend or relative. 18
While credit cards are perhaps the most common way to address a short-term credit need, this
section focuses on other options such as payday loans, overdraft signature loans from a bank or
credit union, installment loans from a consumer finance company, or a pawn shop. Because
surveys suggest that some consumers shopping for small loans may choose among these
options, we consider the trade-offs and challenges inherent in making this decision.
2.3 Shopping Channels

Consumers shopping among small dollar loan options may find that various products are
offered with different prices, terms, and conditions. The cost of a payday loan is typically
communicated as a fee calculated as a percentage of the loan amount, with the entire amount
due on the borrower's next payday. In addition, the lender must disclose an APR. Somewhat
similarly, an overdraft also has an upfront fee and usually is repaid when a consumer next
deposits funds into their bank account, although an overdraft fee is usually fixed regardless of
the amount by which a transaction overdraws an account. Other options, such as installment
and signature loans, carry varying interest rates and are typically repaid over longer periods of
time. Finally, a pawn loan is usually repaid within a month, or the borrower may choose to
simply forfeit the item being held as collateral at the end of the loan term.
18 SUlyeys showing households' consideration of these various strategies when faced with a fmandal short-fall include
Payday Advance Customer Research Cumulatil>e State Researc:h Report, IO Data Corporation (September 2(02),
North CaroJioo Coflsumers After Payday Lending: Altitudes and Experiences with Credit Options, Uni\'ersityof
North Carolina Center for Community Capital (November 2007), Gregory Elliehausen, Afl .4nalysis ofConsumers'
Use 0/ Payday Loons (January 2009), Paydny Lending inAmerica: l'iho Borrows, Where They Borrow, and Ivny,
Pew Charitable Trusts (July 2012), and A Complex Portrait: An framination o/Small-Dollar CreditConsumers,
Center for Financial Ser.'ices Innovation (August 2012).
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445
While the cost of obtaining a loan may be a major consideration when deciding to take on debt
and selecting which credit product to use, it is not the only factor in a consumer's decisionmaking process. For example, in some sUiveys, borrowers of small dollar amounts have
ovenvhelmingly cited the speed, convenience and near-certainty that they will be approved for a
loan as the primary considerations for using these products.19 Likewise, while friends and family
may charge little or nothing to a consumer needing some assistance, there may be concerns
about mixing financial needs with these important relationships that outweigh cost
considerations.20
Many of those decisions are dependent on the loan products for which the consumer can qualify,
with consumers on the subprime end of the credit scale potentially having fewer credit options.
In the case of payday loans, availability is generally dependent on the state in which the
borrower resides, since a significant number of states do not permit loans at the interest rates
these products typicallycarry.21 However, in these (and other) states, residents may be
obtaining internet payday loans.
19 Speed, convenience, and likelihood of approval were top reasons borrrn',ersdecided to use small dollar credit
products in four ua tional surveys. &e Payday .4.dvance Customer Research Cumulatiue State Re5earch Report, 10
Data Corporation (September 2(02), Payday .4.dvante Customer Satis/actiouSuruey, Cypress Research Group (May
2(04), Gregory Flliehausen, All Analysis o/Cow;umers' Use a/Payday LoaIlS (January 2(09), and.4. Complex
Portrait: An Examination a/Small-Dollar Credit Consumers, Center for Financial Services Innovation (August 2012).
20 In a survey of how low and moderate-income North Carolina families managed firumcial shortfalls, 42% noted that
they obtained money from friends and family. See North Caro/illa Consumers.4.fter Payday Lending: .4.ttitude5 and
Experiellce5 with Credit OptiOIlS, University of North Carolina Center for CommunityCapital (Now;mber 2(07).
Similarly, over a quarter of payday borrowers consider taking a loon from a friend or fami ly member, according to two
national surveys. See suJ':ey results in Payday Ad~'Gnce Customer Research Cumulative State Research Report, 10
Data Corporation (September 2(02) and Gregor), Elliehausen, An Analysis a/Consumers' Use 0/ Payday Loans
(January 2(09).
21 Stephens Inc. reports that 13 states and the District of Columbia haw no payday lending storefrouts and an
additional state would no longer authorize the product by mid-:wlO. See Payday Loaf! Industry Update, Stephens
luc. (Juue 6, 20U). There are, hO'ol'e\'eI', a smalluumberof consumers in these states that do rep:>rt using payday
loons in a recent Pew survey. SI! Payday Lending in America: who &Jrrows, where They BoITOW, mid 1\1ly, The
Pew Charitable Trusts (July 2012).
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446
2.4 Product Complexity

Given the diversity of small dollar loans that exists in the marketplace, consumers may have
difficulty comparing these products on an "apples-to-appl5~ basis. It may be challenging to
determine whether taking out a two-week payday loan, pawning a household good for a month,
or gradually paying down a six-month installment loan makes better fi nancial sense. One
standard approach to comparing loan costs is the APR; however, APRs may not be provided in
every case, or include all fees. For example, APRs are not disclosed when a consumer incurs an
overdraft fee, and other products might have application or other fees that are not included in
this calculation. 22 At least one survey suggests that many consumers may not understand how to
use APR to measure the relative costs of different small dollar credit options. 23
Importantly, especially for payday loans, some consumers may overestimate (or fail to give
consideration to) their ability to fully repay a loan, resulting in the need to refinance or
otherwise extend their loan, which can result in considerable additional cost. If consumers do
not understand all their options and potential obligations, they may not fully anticipate their
repayment costs, and may lose the opportunity to choose a different product that might be more
appropriate to meet their needs.
22 For example, "deposit advance" prodnctsoffered by banks tocheckingaccoont customers lIith direct deposit are
structured as open end" lines and the cash advance fee on sllch a line maynol trigger anAPR disclosure.
23 A na tional survey of 1,173 payday borl'O'ol'ers found tha t only 34%were able to cite an APR for a payday loan. Of
those who reported an APR, about half reported a rate that w3S unrealistically low. See Gregory Elliehausen,An
Analysis o/Consumers' Use of Payday T..cans (January 2.009).
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3. Delivering for American

Consumers and Leveling
the Playing Field
The CFPB is authorized to exercise its authorities under federal consumer financial protection
laws to administer, implement, and promote compliance with those laws. To this end, the
Bureau has worked to expand the resources it makes available to consumers and build the
infrastructure necessary for making consumer financial markets work better.
3.1
Resources for Consumers
The CFPB has launched a variety of offices to provide assistance and infonnation to consumers.
The Bureau strives to provide individualized help to consumers based on their specific issues
with financial products and services, and it works to improve financial literacy and capability amongst the public as a whole and consumers who have experienced particular challenges in the
financial markets.
3.1.1
Consumer Response
Consumer Response receives complaints and inquiries directly from consumers. The CFPB
accepts complaints through its website and by telephone, mail, email, fax, and referral.
Consumers submit complaints on the CFPB website using complaint fonns tailored to specific
products, and can also log on tothe secure consumer portal to check the status of a complaint
and revie'o'll a company's response. While on the website, consumers can chat with a live agent to
receive help completing a complaint form. Consumers can also call the Bureau's toll-free
number to ask questions, file a complaint, check the status of a complaint, and more. The
CFPB's U.S.-based contact centers handle calls with little-to-no wait times and can provide
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services to consumers in more than 180 languages and serve hearing- and speech-impaired
consumers via a toll-free telephone number. Cutting-edge technology, including the secure
company and consumer portals, makes the process efficient and user-friendly for consumers
and companies. The CFPB also provides secure channels for companies to communicate directly
with dedicated staff about technical issues.
As Consumer Response processes complaints and responds to inquiries, it continues to seek ne\.."
ways to improve existing processes to make them as efficient, effective, and easy-to-use as
possible. Based on feedback from consumers and companies, as well as its own observations,
Consumer Response identifies new opportunities to improve its processes and implement
changes with each product launch. By applying the lessons learned through previous complaint
function rollouts, Consumer Response has continued to improve its intake process, enhance
communication with companies, and ensure the system's ease-of-use and effectiveness for
consumers, while providing services trusted by consumers and companies alike.
3.1.2 Consumer Education and Engagement

The CFPB's Consumer Education and Engagement Division is responsible for developing and
implementing initiatives to educate and empower consumers to make better-informed financial
decisions. Improving financial literacy and capability encompasses many short and longer-term
efforts, including education and engagement with information and tools designed to provide
clear and meaningful assistance to consumers when they need it.
Reaching out to consumers is essential to the work of this division. From July 1, 2012 through
December 31, 2012, the division's offices engaged \vith different groups across the country
through more than 240 listening sessions, town halls and roundtables, visits to military
installations, and other stakeholder events. These and other opportunities to hear directly from
consumers about their financial needs, aspirations, and experiences help inform all of the
Bureau's work. Through this outreach work, the CFPB has connected to more than 4,100
stakeholder organizations that were involved in these events.
As a 21st-century agency, the Bureau has focused on bringing financial decision-making tools
and information to consumers through an accessible online format. In 2012, a steadily

increasing number of consumers took advantage of these offerings. The Bureau's website
received more than five million unique views in the past year. The CFPB estimates that more
than 3,750,000 of those were to areas of the site providing consumer tools, information, and
assistance.
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3.1.3 Financial Education

The Bureau's Office of Financial Education (OFE) has engaged a variety of communities and
stakeholders in its work. OFE has continued to prioritize outreach to key stakeholders, including
financial educators and community leaders, and directly with consumers, through webinars,
listening sessions, and large consumer events. Much ofOFE's outreach has prioritized
innovation to solve common financial challenges for consumers by holding a number of events
around the country to assess need and to establish its priorities in this area.
In its efforts to engage with a larger American audience, OFE has produced some of its core
consumer education materials in Spanish, and provided radio intetvie\'/s both in Spanish and
English to appeal to a broad audience. OFE also received more than 100 comments from a range
of organizations, individuals, financial institutions and other entities in response to a Request
for Information (RFI) on Effective Financial Education.
OFE has also added to its research and innovation portfolios, procuring the services of outside
experts to develop metrics for success in financial education and to test solutions for consumers
as they make regular, everyday financial decisions.
3.1.4 Consumer Engagement

The Office of Consumer Engagement (CE) continues to encourage the public to participate in the
Bureau's work by developing programs, initiatives, and digital experiences that help consumers
make informed financial decisions.
CE continues to improve and build out the Bureau's online presence with innovative, userfocused, and data-driven approaches to social media and web development. Through ra<;earch
and user ta<;ting, CE has been able to tap into the needs, habits and interests of consumers, thus
allowing the team to create opportunities to engage the public at the moments we can be most
useful to them.
In particular, CE has focused on building an online consumer experience through the beta
version of its Paying for College project. This online module guides users through the primary
decision points of the college decision-making process and offers tools that help users to:
Find financial aid and choose a loan;
Compare financial aid and college costs;
Manage college money; and
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Repay student debt

CE continues to collaborate with divisions across the Bureau on ways to best engage the public
through digital media.
3.1.5 Servicemember Affairs

The CFPB's Office ofSetvicemember Affairs (OSA) conducted 82 outreach events in 2012,
delivering consumer financial information to more than 31,000 military and veteran consumers
to help them make better informed financial decisioll.'i.
More specifically, this figure includes reaching out to servicemembers where they live and work,
by visiting 10 military ill.'itallatioll.'i/National Guard units, and participating in six town halls and
15 roundtable discussioll.'i with senior military leaders from July 1, 2012 through DlX:ember 31,
2012. At these outreach events, the Servicemember Affairs team listened to seryicemembers
discuss the financial challenges they face, observed financial education training, and provided
educational materials. In addition to the military units/installations visited, OSA participated in
40 outreach events sponsored by external organizations seeking additional educational
information about OSA and the CFPB. OSA also launched Facebook and Twitter accounts
specifically to selVe the military and veteran communities. By incorporating the use of digital
and social media channels into the delivery methodolOO"oY for coll.'iumer financial education, QSA
reached approximately 2.8 million more coll.'iumers.
OSA awarded a contract to develop an effective "just enough and just in t i me~ financial
education experience designed to equip Delayed Entry Program (DEP) participants (those who
have committed to join the military but not yet been sent to boot camp) with the information
and education needed to make sound financial decisions in predetermined target areas. The
DEP education program aims to offer experiential education that engages the interest and caters
to the learning style of the recruit demographic. Due to the varied timelines and geographical
locations of the future recruits in DEP and to ensure the curriculum's availability across the
selVices, course content and materials will be made available through an e-leaming platform
that DEP personnel can access regardless of time or location. This experience should also set the
stage for future financial education efforts.
Collaboration and building upon viable outreach nehvorks was a key focus throughout 2012.
OSA connected with the Departments of Defense, Veterans Affairs, Justice, and Labor to raise
awareness of the CFPB's mission and OSA's specific efforts on behalf of the military and veteran
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communities. At the state level, efforts have centered on introducing state and local resources to
the military community. Military consumer-focused events included the participation of 14 state
National Guard Adjutants General and the Attorneys General of 11 states.
3.1.6 Older Americans

The Consumer Education and Engagement Division's Office for Older Americans (OA) has
continued its outreach efforts nationwide with its core constituency, key public officials,
financial institutions, industry, advocates, and other stakeholders. OA's mission is "to facilitate
the financial literacy of individuals who have attained the age of 62 or more ... on protection from
unfair, deceptive, and abusive practices, and on current and future financial choices, including
through the dissemination of materials to seniors on such topics." OA participated in 46 events
from July 1,2012 through December 31, 2012, reaching more than 2,050 participants.
OA's outreach work is raising awareness of the critical problem of financial exploitation and
unfair, deceptive, or abusive practices targeted at older people. OA is also building on its
outreach work to help foster local networks to prevent financial harm directed at older people.
In support of its mission, Hubert H. "Skip" Humphrey III, Assistant Director for OA, testified
before the U.S. Senate Special Committee on Aging on November 15, 2012 regarding OA's many
initiatives to combat the crisis of financial exploitation facing older Americans. 24
Specific examples of these outreach efforts include helping coordinate Older American
Protection Networks in four states, representing the CFPBon the federal Elder Justice
Coordinating Council, which consists of 11 federal agencies that playa role in addressing elder
abuse, and collecting and reviewing comments submitted in response to the CFPB's RFI
Regarding Senior Financial Exploitation. The Bureau received over 1,200 comments in response
to the RFI, providing invaluable public participation to inform OA's work.
The RFI has also provided important input for OA's work on an upcoming report to Congress
and the Securities and Exchange Commission (SEC) on senior financial advisor certifications
and designations, pursuant to Section 1013(g)(3)(C) of the Dodd-Frank Act. That report will
24 Assistant Director Humphrey's testimony maybe found inAppendL~ F.
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address consumer issue.<; relating to certifications or designations of financial advisors for

seniors.
Other initiatives underway include developing consumer guides to help fiduciaries handle
finances on behalf of older consumers, a guide to help identify and intervene when financial
exploitation occurs in congregate living facilities, and developing, along with the FDIC, a
community education and awarene.<;s program called Money Smart for Older Americans, which
focuses on preventing, recognizing, and reporting elder financial exploitation targeting older
consumers, family caregivers and other key audiences.
3.1.7 Students
Pursuant to Section 1035 of the Dodd-Frank Act, the CFPB's Student Loan Ombudsman
submitted a report to the Director of the CFPB, the Secretary of the Treasury, the Secretary of
Education, and Congress in October 2012. The report offered analysis of complaints from
private student loan borrowers, and was informed by nearly 3,000 complaints, as well as input
from borrowers and stakeholders.
The report found that some private student loan borrowers are experiencing similar issues to
borrowers struggling with mortgages. For example, borrowers complained about the difficulty in
negotiating a lower payment, as well as issues they faced when loans and servicing rights change
hands.
In a separate report, the Student Loan Ombudsman, in coordination with OSA, identified a
unique set of issues facing servicemembers with student loans. The report identified problems
faced by servicemembers when attempting to invoke their rights afforded by the Senice
Members Civil Relief Act.
The Bureau has developed more tools to help consumers make better financial decisions about
paying for college and managing student debt. In July 2012, the CFPB launched the Student
Loan Debt Collection Assistant to help borrowers avoid costly penalties and fees when their
loans are in collection. As part of the Paying for College suite of tools, the Bureau launched
Repay Student Debt, a combined, expanded version of our tools.
Based on public feedback received in response to a prototype launched in April 2012, the CFPB
released the next iteration of Compare Financial Aid and College Cost, a tool to help students
and families make smarter choices when weighing financial aid offers. The Bureau also issued a
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special guide to assist students when choosing a checking account and accessing financial aid
offers.
3.1.8 Financial Empowerment

Since its launch in May 2012, the Office of Financial Empowerment (Empowerment) has
conducted extensive outreach to consumers and stakeholders from around the country.
Empowerment participated in five listening sessions in San Francisco, CA, New York, r-,ry, St.
Louis, MO, Cleveland, MS and Dallas, TX. The team conducted field research focused on
organizations and companies that provide innovative programs and services designed to build
the financial capability of underserved and vulnerable consumers. It also participated in
community events and conferences focused on low-income issues.
On November 28-29, 2012, at the CFPB's headquarters in Washington, DC, Empowerment
brought together 125 external stakeholders to discuss opportunities to make consumer financial
markets work better for low-income and economically vulnerable consumers. This meeting
included Bureau leaders, local, state, and federal financial regulators, senior government and
agency officials, and leaders and practitioners from indlL'itry, academia, and nonprofit
organizations who have been developing and evaluating innovative initiatives to address the
financial services needs of low-income and economically vulnerable consumers.
Empowerment launched two major projects in September 2012. The fi rst is a three-phase
information-gathering effort to better understand whether bundled financial products and
services are effective in building the financial capability of consumers. This effort will help gauge
whether programs designed to build the credit and/or savings of consumers are more effective if
they include a bundled secondary product or service. This phase is designed to lead to further
stages that will include an evaluation of two programs that currently use the bundled products
and/or services strategy, and eventually a pilot phase that will test t\vo "idear programs based
on the lessons learned from the previous two stages. The second project is the development of
Financial Empowerment Training for front-line staff, like social workers or benefits
administrators, for organizations that provide services directly to low-income and economically
vulnerable consumers.
Empowerment is also working with other federal agencies to streamline and integrate federal
resource services designed to make consumers more financially capable and stable. Current
work includes coordination with the Department of Labor's Office of Disability Employment
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Policy (DOEP) in a joint effort to identify opportunities to promote financial capability strategies
to selected OOEP grantees.
3.2 Outreach
In addition to its efforts to engage and educate particular populations, the CFPB has hosted
events throughout the country to infonn and receive input about its work on issues related to
consumer financial products and services. More than 1,000 consumers have made their voices
heard by participating in town halls and field hearings convened by the eFPB - such as one on
credit reporting in Detroit, MI and one on debt collection ill Seattle, WA. The CPFB has acti\"ely
solicited public input on key policy initiatives at the launch of Project Catalyst in Silicon Valley,
CA, and at the inaugural meeting of the Consumer Advisory Board (CAB) in SI. Louis, MO.
Director Cordray speaks at an e;-em on credit reporting in Detroit, Michigan
The eFPB um"eiled Project Catalyst as part of its effort to foster consumer-friendly innovation in
the marketplace. The Bureau believes markets work best when they are open to new ideas, and
that the insights and innovations that come from looking at problems and solutions from new
angles hold great potential in our efforts to achie\"e our mission of making the consumer finance
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market work for all consumers. Project Catalyst is designed to open lines of communication and
foster collaboratioIl.'i that promote consumer-friendly innovation. In addition to conducting
ongoing outreach and forums for discussion, the CFPB has launched a new section of its website
where innovators can obtain relevant information, propose ways the Bureau can make
innovation easier, or suggest pilot projects to develop and test new market ideas.
In conjunction with field events, Director Cordray and Deputy Director Date held roundtables
with community banks, credit unions, and other members of the financial services industry as
part of our continuing commitment to engage with financial services providers. The Bureau has
actively solicited the perspectives of consumer and civil rights groups and has held roundtables
with community-based organizations across the country. Since July 2012, the CFPB's DCA has
engaged thousands of community group representatives through more than 100 meetings,
briefing calls, and public appearances. Topics discussed include mortgage, credit cards, payday
loans, student loans, bank accounts, prepaid cards, credit reporting and scoring, debt collection,
remittances, and more.
As with industry outreach, the Bureau has ensured that consumer groups' perspectives inform
its internal deliberations on policy initiatives. Bureau representatives have met with hundreds of
industry representatives, and Director Cordray and senior CFPB leadership have delivered
several speeches at widely-attended industry and nonprofit conferences. 25
25 A list of speeches given in 2012 byCFPB personnel may be fou nd in Appendix G of this report.
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Senior CFPB leadership Idd ...stt cornrner.tslt an ~nt <>Il d.~ alIled:ion in SeatO.. Wlsr.i,;gtOll.
3.3 Partnerships
The Bureau has furthered many existiltg partnerships and formalized se\'eral new ones.
Todate, the Bureau has signed numerous memoranda of understanding (MOUl \lith
intergol-ernmental partners, including federal agencies, state fi na ncial regulatory entities, state
attorneys general. and mun icipal law nforrement agencies.:!IS The Bureau has also actively
solicited the perspectil-es (If ooll.'mmer and civil rights groups.
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Bureau personnel also testified before Congress on 17 occasions between January 1, 2012 and
December 31, 2012 to discuss policy, operations and budget matters.27
3.3.1
Office of the Consumer Advisory Board and Councils
In addition, the Bureau has established the Office of the Consumer Advisory Board and
Councils, which is charged with managing the Bureau's advisory groups and serving as the
liaison behveen advisory group members and the Bureau. It oversees the Bureau's engagements
with external stakeholders and includes the:
Consumer Advisol)' Board (CAB);
Community Bank Advisory Council (CBAC);
Credit Union Advisory Council (CUAC); and
Academic Research Council (ARC)
The Office of the Consumer Advisory Board and Councils is part of the External Affairs Division.
To manage these bodies, the Office of Consumer Advisory Boards and Councils:
Regularly facilitates discussions between the Bureau and advisory board/council
members;
Recommends policy and associated strategies as suggested by advisory boards and
councils;
Manages the selection process for the Bureau's advisory boards and councils;
Conducts agenda setting for advisory board and council meetings; and
Manages the policies and procedures for the constitution and management of advisory
boards and councils.
These groups will meet at least twice per year and offer vital insight and perspective of financial
service providers as the Bureau strives to issue thoughtful, research-based rules.
27 CFPB testimony before Congress may be found in AppendL~ F of this report.
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ROLE OF THE CONSU MER ADVISORY BOARD
Section 1014(a) of the Dodd-Frank Act states:

The Director shall establish a Consumer Advisory Boord to advise and consult with the
Bureau in the exercise of irs functions under the Federal consumel'jinanciallaws, and
to provide infonnation on emerging practices in the conSi/mer financial products or

services industry, including regional trends, concerns, and other relevant
information. 28
The Consumer Advisory Board and the other advisory councils help the Bureau solicit external
stakeholder feedback on a range of topics, including consumer engagement, policy development

and research, and from a range of actors, academics, industry, community members and
advocates. Advisory boards and councils may consult on a variety of cross-cutting topics, report
on meetings, and provide minutes and/or summaries of their meetings. Members of boards and
councils will serve for limited, specified terms.
MEMBERSHIP AND PUBLIC NOMINATING
PROCESS OF THE CONSUMER ADVISORY BOARD
Section 1014(b) of the Dodd-Frank Act states:

In appointing the members of the Consumer Advisory Boord, the Director shall seek to
assemble experts in consumer protection,financial services, community development,
fair lending and civil rights, and consumer financial products or services and
represel1tatives ofdepository institutiol1s that primarily serve underserved
communities, and representatives ofcommunities that have been significantly
impacted by higher-priced mortgage loans, and seek representation of the interests of
covered persons and consumers, without regard to party affiliation.29
Following these statutory guidelines, the Bureau invited e:xternal experts, industry
representatives, consumers, community leaders, and advocates to apply to be a member of the
28 Dodd-Frank Act, Pub. L No. 111-203, 1014(a).

29 Dodd-Frank Act, Pub. L No. 111-203, IOI4(b).
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Consumer Advisory Board. Additionally, the Bureau publishoo a notice for nOOlinatiOlls on its
website, distributed a notice v.i dely through mass email distnbutions, and published a notice
outlining the functions of the Board and soliciting nominations for members to serve on the
Board in the Federal Register. In responsetothis call for nominations, the Bureau receil.roO\-er
1,100 unique candidate nOOlinations for membership on the Board. On September 12, 2012, the
Bureau announced the appointment of 2.5 consumer I'-lperts to the Consumer Ad\isory Board 3G .
The inlllgund members 01 11-. . Cocsum.r AI";""" brd. meeting inSlLwi .. htisswri
INAUGURAL MEETINGS OF THE CONSUMER

ADVISORY BOARO AND THE OTH ER COUNCILS
The Bureau held the inaugural meeting of the Consumer Alh"isory Board in St.louis, MOon
September :17-28, 2012, in\;ting members of the public to watch 3 portioo of the meeting and to
prolide testimooydirectlyto CAB members 011 the financial issues that affect their
JO Th.IIlf.I>uo..,,,,,,&t I&d list of m.C1be" Cloy be round It

bttp:/tw-COIlSIIClerfilll<l<qrrr/pm<mlto-/tomIlmer-fimonau.protu:ti""ba.--...
od,t.ory-boordmembers!.
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communities. Director Cordray provided remarks at the event that are available on our
website. 31
The inaugural meetings of the Community Bank Advisory Council and the Credit Union
Advisory Councils were held, respectively, on October 11, 201 2 and October 12, 2012.
For more information about the CAB and the other CFPBadvisory bodies, please visit our
website.
31 Director Cordray's remarks may be read at http://I1,,",'W.consumerfinance.gov /~peeches/prepared-remarks-by

ric hard -rordray-at-the-inaugural-consumer-advisory-board-meelingf.
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4. Regulations and Guidance

Since the issuance of the July 2012 Semi-Annual Report, the Bureau issued a number of
proposed and final rules on mortgage-related issues, in anticipation of meeting a January 21,
2013 deadline under the Dodd-Frank Act, as well as a number of non-mortgage related
proposed and final rules on various other matters within its authority. Along with the issuance
of these new rules, the CFPB is also working to facilitate industry compliance. In addition, the
Bureau continues to implement suggestions received in response to a Bureau RFI seeking public
comments on potential projects to streamline Bureau regulations.
4.1
Implementing Statutory Protections
The CFPB has recently finalized a number of rules implementing changes made by the DoddFrank Act to the laws governing various aspects of the mortgage market, including originations
and servicing of mortgages. In 2012, the Bureau issued a series of proposed mles for public
comment after months of preparation and outreach, including several small business review
panels. The Bureau analyzed the comments received on those proposals and prepared the final
mles, as well as various final rules for proposals inherited by the Bureau from the Federal
Reserve Board. These rules will provide significant improvements to the mortgage process that
will benefit both consumers and the mortgage industry alike through strengthened consumer
protections and increased efficiencies. The Bureau issued the following final rules in January
2013:
32
A rule implementing Dodd-Frank Act amendments to the Truth in Lending Act (TILA)
requiring that creditors make a reasonable, good-faith determination of a consumer's
32 Links to fina l and proposed rules discussed in this section are available at: consumerfinance.gO\'!regulations/'
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ability to repay any consumer credit transaction socured by a dwelling (excluding an

open-end credit plan, timeshare plan, reverse mortgage, or temporary loan), establishing
certain protections from liability under this requirement for "qualified mortgages,~ and
limiting prepayment penalties. The rule also requires creditors to retain evidence of
compliance with the rule for three years after a covered loan is consummated.
Rules implementing new Dodd-Frank Act requirements in the Real Estate Settlement
Procedures Act (RESPA) and in TILA related to mortgage servicing. The rule amending
Regulation X, which implements RESPA, addresses servicers' obligations to correct
errors asserted by mortgage loan borrowers, to provide certain information requa<ited by
such borrowers, and to provide protections to such borrowers in connection with forceplaced insurance. Additionally, this rule addresses servicers' obligations to establish
reasonable policies and procedures to achieve certain delineated objectives, to provide
infonnation about mortgage loss mitigation options to delinquent borrowers, to
establish policies and procedures for providing delinquent borrowers with continuity of
contact with servicer personnel capable of performing certain functions, and to evaluate
borrowers' applications for available loss mitigation options. Further, the rule modifies
and streamlines certain existing servicing-related provisions of Regulation X. The rule
amending Regulation Z, which implements 11 LA, includes requirements concerning
notices of initial rate adjustments for adjustable rate mortgages (ARMs), periodic
statements for residential mortgage loans, prompt crediting of mortgage payments, and
responses to requests for payoff amounts. This rule also amends current rules governing
scope, timing, content, and fonnat of disclosures to consumers regarding the interest
rate adjustments of their variable-rate transactions.
A rule implementing certain amendments to TILA made by the Dodd-Frank Act that
lengthens the time for which a mandatory escrow account established for a higher-priced
mortgage loan must be maintained and exempts certain transactions from the escrow
requirement, including creating an exception for certain small servicers in rural or
undersenred areas.
A rule implementing Dodd-Frank Act changes to l1LA regarding loan originator
compensation, qualifications of and registration or licmsing of loan originators,
compliance procedures for depository institutions, mandatory arbitration, and the
financing of single premium credit insurance. The rule also revises or provides additional
commentary on restrictions on loan originator compensation, including application of
these restrictions to prohibitions on dual compensation and compensation based on a
term of a transaction or a proxy for a term of a transaction, and to rocordkeeping
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requirements. The rule also establishes tests for when loan originators can be
compensated through certain profits-based compensation arrangements.
An interagency rule implementing Dodd-Frank Act amendments to TIIA that requires
appraisals for ~higher- risk mortgages,~ including, for certain mortgages, requiring
creditors to obtain an appraisal or appraisals meeting certain specified standards, and
providing applicants .1th a notification regarding the use of the appraisals and a copy of
the written appraisals used.
A rule implementing a Dodd-Frank amendment to the Equal Credit Opportunity Act
(ECOA) that requircs creditors to provide applicants with free copies of all appraisals
and other written valuations developed in connection with an application for a loan
secured by a first lien on a dwelling, and requircs creditors to notify applicants in writing
that copics of appraisals will be pro\1ded to them promptly.
A rule implementing Dodd-Frank Act amendments to TILA that expands the types of
mortgage loans that are subject to the protections of the Home Ownership and Equity
Protection Act of 1994 (HOEPA), revises and expands the tests for coverage under
HOEPA, and imposes additional restrictions on HOEPA mortgage loans, including a preloan counseling requirement. The rule also implements other Dodd- Frank Act
amendments to TIIA and RESPAthat impose certain other requirements related to
homeownership counseling, including a requirement that consumers receive information
about homeownership counseling providers.
In addition, since the July 2012 Semi-Annual Report, the Bureau has issued other proposed and
final rulcs, including the following:
in November 2012, the Bureau proposed to amend the rules implementing the credit
card ability to pay pr0\1sions ofTiIA to addrcss concerns that the current rules unduly
limit the ability of spouses and partners not working outside the home toobtain credit
cards based on the income of the other spouse or partner.
In August 2012, the Bureau issued a final rule that providcs a "safe harbor~ provision
exempting from the requirements of the Bureau's Regulation E, which implements the
Electronic Fund Transfer Act, as amended by the Dodd-Frank Act, those who, in the
normal course of business, provided 100 or fe'wer remittance transfers in the current
calendar year. This amendment \\111 make the remittance transfer process easier for
institutions that handle 100 or fewer remittances per year. The August 2012 rule also
adjusts rules regarding transfers that consumers schedule several days in advance. In
December 2012, the Bureau proposed three substantive amendments to the remittance
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nile, which would temporarily delay the February 7, 2013 effective date of the rule and
provide additional clarity regarding disclosures and error resolution procedures. On
January 22, 2013, the Bureau issued a final nile temporarily delaying the February 7,
2013 effective date.
In January 2013, concurrently with issuing its ability to repay/qualified mortgage nile,
the Bureau issued a proposed nile proposing certain amendments to the rule, including
exemptions for certain nonprofit creditors and certain homeownership stabilization
programs and an additional definition of a qualified mortgage for certain loans made and
held in portfolio by small creditors. The Bureau also sought feedback on whether
additional clarification is needed regarding the inclusion ofloan originator
compensation in the points and fees calculation.
The Bureau continues work to finalize the proposal it issued in July 2012 that would, among
other things, combine certain disclosures that consumers receive in connection with applying
for and closing on a mortgage loan under TILA and RESPA, as required by the Dodd-Frank Act.
The Bureau also continues work to finalize the proposal it issued in April 2012 with respect to
fees charged by credit card issuers prior to the opening of an account, and continues working on
an interagency basis to complete rulemakings related to appraisals and implementation of the
Expedited FundsAvaiiability Act.
As the Bureau completes work on these pending rulemakings, it is also in the process of
analyzing and prioritizing additional projects. It expects, for example, to accelerate work on
other rule makings that are mandated under the Dodd-Frank Act, such as amendments to the
Home Mortgage Disclosure Act (HMDA) to require creditors to collect and report certain
additional lending data. In addition, the Bureau is in the process of assessing infonnation
gathered in the past year concerning a variety of consumer financial products and services
besides mortgage loans to determine whether rulemakings are warranted to address other
markets. In particular, the CFPBhas issued a number of RFls, an advance notice of proposed
rulemaking, and congressionally mandated and other reports in the past year concerning a wide
variety of markets and consumer financial issues. The Bureau expects, for example, to issue a
proposed rule with respect to prepaid cards in 2013.
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4.2 Interpreting and Streamlining Inherited

Regulations ; Facilitating Compliance
with New Regulations
The CFPB continues to work with consumer and industry stakeholders to interpret and
streamline regulations that implement existing federal consumer financial protection laws.
These regulations were issued previously by other federal financial regulators and transferred to
the Bureau in July 2011. The Bureau is also working to find ways offacilitating industry
compliance with newly issued Bureau rules.
In 2012, the Bureau issued interpretive guidance 33 on a variety of topics, including interpreting
regulations concerning mortgage loan originator compensation, licensing requirements for loan
originators under the Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (SAFE
Act), and reaffirming the applicability of the disparate impact doctrine under ECOA.
The CFPB is also considering opportunities to streamline, modernize, and hannonize
regulations that it inherited from other federal agencies. The Bureau issued an RFI in December
2011 on this topic seeking broad stakeholder input, and as a result of the comments received,
has identified several priority areas for regulatory action. For example, the proposal that the
Bureau issued in November to amend the ability-to-pay regulations under the Credit Card
Accountability Responsibility and Disclosure Act of 2009 (the Credit Card Act) was advocated
by a number of industry participants responding to the streamlining RFI. Similarly, the Bureau
is carefully exploring methods to reduce the burden of HMDA reporting while simultaneously
increasing the value of the information collected.
In addition, the CFPB is assessing ways to facilitate industry compliance with newly-issued
regulations. The Bureau has determined that one important way to help reduce compliance
burdens is to assist regulated entities, especially community banks, credit unions, and small
entities, in understanding and complying with the mles. For example, in connection with the
remittance mle, the Bureau has engaged in outreach and provided educational materials to
industry. In October 2012, the Bureau issued its International Fund Transfers Small Entity
33 00llS11merfinanre.gov/guidallce/.
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Compliance Guide.Mone industry representative remarked upon reading the Guide, "I
commend the CFPB for providing a guide that is so informative.... The guide presented the
requirements of the remittance rule in a clear and concise manner in a format that could be
understood by all levels of employees. ~ The Bureau also held a webinar in October 2012
explaining the remittance rule that was similarly well received. J4 The webinar was viewed live by
over 3,000 participants and more than 1,000 individuals have viewed the archived webinar
online. As one industry professional stated in an e-mail to the Bureau, "This webinar was much
better than one I paid $300 for from a reputable banking resource. .. Great job, CFPB! ~ In
addition, Bureau staff have participated in a large number of conferences to discuss the
remittance rule, and have handled informal inquiries from a myriad of remittance service
providers. The Bureau intends to engage in similar activities in the coming months to facilitate
understanding of, and compliance with, the mortgage regulations that the Bureau has issued.
The Bureau is also working to develop opportunities to test alternatives to currently-mandated
disclosures which may enhance the efficacy of such disclosures and/or reduce costs. In
December 2012, the Bureau issued a proposed Policy to Encourage Trial Disclosure Programs
and invited public comment on that proposed policy. The Bureau expects to finalize the policy
shortly so as to create room for such trial disclosures.
Finally, the CFPB promulgated supplemental ethics regulations for Bureau employees,
establishing restrictions on outside employment and business activities, prohibitions on the
ownership of certain financial interests, restrictions on seeking, obtaining, or renegotiating
credit and indebtedness, prohibitions on recommendations concerning debt and equity
interests, disqualification requirements based on credit or indebtedness, prohibitions on
purchasing certain assets, and restrictions on participating in particular matters involving
outside entities. 35
34Remarks, the webinar, and a slide presentation on the remittance ntles may he found at
www.ronsumerfinan~ .govfblog/remillance-rule-session/.
3S oonsllmerfinance.gov/ reglliations/ .
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5. Supervision
The eFPE's supervision program seeks to ensure that businesses that provide financial products
and services to consumers comply with federal consumer financial laws. Initially, the CFPB's
5upenrision office was organized into hvo groups, one addressing the supervision oflarge banks
and the other focusing on nonbank supervision. In December 2012, Supervision announced the
reorganization of its headquarters staff into an examinations team and a policy team. lhis
realignment replaces the previous organizational stmcture and is consistent with the Bureau's
mission to protect consumers across financial markets without regard to the charter of the
provider. The examinations team focuses on the processes vital to accomplishing the CFPB's
examination function, including recruitment, training, and commissioning of examiners, the
implementation of examination policies and procedures, and the planning and execution of
examinations appropriately in light of the Bureau's resources and priorities. The policy team
ensures that policy decisions for Supervision are consistent with both the law and our mission,
and that they are consistent across markets, charters and regions. The Supervision Policy office
is organized by product or service market rather than bytype of service provider or financial
institution.
5.1
Supervisory Activities
On October 31,2012, the Office of Supervision issued three publicdocuments:

SUPERVISORY HIGHLIGHTS: FALL 2012
The CFPB supervises certain financial institutions and service providers to determine their
compliance with applicable federal consumer financial laws and regulations and to help ensure
that markets for financial products and services work in a fair and transparent way for
consumers and the businesses that serve them. As part of its commitment to transparency, the
CFPB has issued Supervisory Highlights: Fall 2012, a periodic publication that apprises the
public and the financial services industry about its supervision and examination program,
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including significant concerns discovered during the course of its completed work. The CFPB
believes this communication will help providers of financial products and services better
understand steps they can take to fully comply with federal consumer financial laws and protect
against the risk ofharm to consumers. This first edition of Supervisory Highlights emphasizes
the need for fina ncial institutions to implement sound compliance management systems, and
discusses issues noted in three key product areas: credit cards, credit reporting, and
mortgages. J6
SUPERVISION AND EXAMINATION MANUAL, VERSION 2
The CFPB's Supervision and Examination Manual guides CFPB examiners in overseeing
companies that provide consumer financial products and services. In Version 2, the Manual has
been updated to restate outdated regulatory citations with new CFPB citations, reflecting the
rulemaking authority for federal consumer financial laws which was transferred from other
federal agencies to the CFPBby the Dodd- Frank Act. CFPB regulations are codified in Title 12,
Chapter X, of the Code of Federal Regulations.
The Manual also incorporates updated interagency examination procedures based on revisions
to (1) IlIA, and its implementing Regulation Z, pursuant to the Credit Card Accountability,
Responsibility and Disclosure Act of 2009 and (2) the Fair Credit Reporting Act (FCRA), that
requires the disclosure of credit score and related information when a credit score is used in
taking an adverse action or in risk-based pricing. In addition, it provides newe.xamination
procedures covering short-term, small-dollar lending, the Secure and Fair Enforcement for
Mortgage Licensing Act, and consumer reporting. It includes updated guidance and procedures
for compliance with ofRESPA in mortgage originations, and incorporates the June 21, 2012
Interagency Guidance on Mortgage Servicing Practices Concerning Military Homeowners with
Permanent Change of State Orders.37
J6 Supen>isory Highlights, Fall20l2 can be found al: http://files.consumerfinanC1!.gov/f/201210_dpb_supervisory-
highlights-fall-2oI2.pdf.
37 The updated CFPB Supervision and E.xamination Manual can be found at:
http://files.oollsumerfinance.gov/f/20 1210_cfpb supervision-and-examinat iOll-mallual-Y2.pdf.
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EXAMINATION APPEALS POLIC Y
The CFPBhas issued a new policy that allows supervised entities that receive final, less than
satisfactory ratings on their reports of examination to request review of their rating by CFPB
officials not involved in the examination or determination of the rating. Supervised entities may
also appeal adverse findings conveyed in a supervisory letter. This new appeals policy promotes
the CFPB's goals of establishing constructive relationships with supervised entities and
maintaining a fair and factually based supervision program. It will help assure consistency in
ratings, and will encourage greater industry compliance with applicable laws and regulations
and better markets for consumers. 38
5.2 Supervisory Guidance and Examination

Procedures
CFPB BULLETIN : MARKETING OF CREDIT CARD ADD-ON PRODUCTS
On July 18,2012, the CFPHissued Bulletin 2012-06, entitled "Marketing of Credit Card Add-on
Produ cts~.
Credit card issuers market "add-on~ products to card users, including debt
protection, identity theft protection, credit score tracking, and other products that are
supplementary to the credit provided by the card itself. The CFPE's supervisory experience
indicates that some credit card issuers have employed deceptive promotional practices for addon products. They have failed to disclose important product terms and conditions, enrolled
consumers in programs without their affirmative consent, billed for services that were not
activated or performed, and misled consumers by the marketing and sales practices employed.
This Bulletin outlines the CFPB's expectation that institutions under its supervision and their
service providers offer such products in compliance with provisions of law, including DoddFrank Act prohibitions against deceptive practices, TILA, ECOA, and other applicable federal
laws and regulations.
38 TheAppeals Bulletin can be found at: http ://files.ron5llmerfinance.gov/f/20121Q_d'pb __ bulletin_5lIpelVisoryappeals-process.pdf.
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The Office of Supervision has issued new examination procedures in three broad areas, which
are now incorporated into the Supervision and Examination Manual:
LARGER PARTICIPANT RULES
Pursuant to provisions of the Dodd-Frank Act, the CFPBgenerally has authority to supervise
nonbank covered persons of all sizes in the residential mortgage, private education lending, and
payday lending markets. In addition, the CFPBhas the authority to supenrise "larger
participant[s]" of markets for other consumer financial products or services, as the Bureau
defi nes by rule.
On July 20, 2012, the Bureau issued a final rule to define larger participants in the consumer
credit reporting market. This final nile facilitates the supervision of nonbank covered persons
active in that market. In September 2012, the Bureau released examination procedures related
to this rule, and since then has begun exercising its supervisory authority in this market.
Further, in October 2012, the Bureau issued a final rule to define larger participants of the
consumer debt collection market, bringing those entities under its supenrisory and examination
authority. The Bureau also released examination procedures fo r this market and held a field
hearing in Seattle, WA on October 24, 2012 to receive public feedback. 39 The nile and related
examination procedures became effective on January 2, 2013. 40
RULES ESTABLISHING SUPERVISOR Y AUTHORITY OVER CERTAIN PERSONS
POSING RISKS TO CONSU MERS
The Bureau has also proposed a nile to establish supervisory authority over any nonbank entity
that it has reasonable cause to determine is posing a risk to consumers with regard to the
offering or provision of consumer financial products or senrices. 41 The proposed nile would
39 The video for this event may be \;ewed at www.oonsumerfinance.gov/blog/categoJ)'/debt-oollection/ andDirector

Cordray's remarks forthee\'ent may be viewed at . . ."oIw.consumerfinance.gov/sprecltes/prepared-remarks-brrichard-eordrar-at-the-public'field'hearillg-on-debt-coUection-practices/.
..., httll://Y,"OW.gpo.gov/fds),s/pkgjFR-:w 12-12-07/pdf/2012-29438.pdf.
41 hH ps://wW.'Jederairegister.gO'l,/articies/2012/0S/25/2012-12718/procedurai-ruies-to-estabiish-supervisoryaUlhorily-owr-certain-nonhank-rovered-persons-based-on.
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establish a process for the CFPBto give notice to the nonbank entities of such determinations
and would provide them with a reasonable opportunity to respond. The proposed rule would not
impose new substantive consumer protection requirements on any nonbank entity. The Bureau
anticipates that this rule will be finalized in 2013.
EDUCATION LOANS
On December 17, 2012, the CFPBpublished procedures it will use in examining private student
lenders. These procedures will help CFPBexaminers ensure that private student lenders comply
with applicable federal consumer financial laws, including TIIA, the Electric Fund Transfer Act,
the Fair Debt Collection Practices Act, the FC RA, ECOA, and the Gramm-Leach- Bliley Act.
5.3 Information Sharing With State

Regulators
The Office of Supervision has continued to expand its information sharing outreach to state
regulators, and now has in place information sharing MOUs with 61 state regulatory agencies in
49 states, the District of Columbia, and Puerto Rico. On December 6, 2012, the CFPBissued a
Statement of Intent for Sharing Information with State Banking and Financial Services
Regulators. Under an access agreement with the State Regulatory Registry, a subsidiary of the
Conference of State Bank Supervisors, the Bureau will have access to state regulatory and
licensing information in the Nationwide Mortgage Licensing System.
5.4 Examiner Training and Commissioning

The CFPB's field examination work is carried out by a highly qualified and diverse examination
staff that has broad experience in planning and conducting examinations of financial
institutions and businesses supervised by the CFPB. In August 2012, 89 experienced examiners
became commissioned CFPBexaminers, based on their prior experience and commissioning at
other federal agencies.lbe CFPB is continuing to develop its own examiner commissioning test,
which will be based on the CFPB's examiner training strategy and components. The examiner
training component includes, among other items, the Bureau's Fair Lending Examination
Techniques course. Examiners who complete the training and pass the test that the CFPB adopts
will become commissioned CFPB examiners.
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5.5 Technology
The Bureau has continued to build out its technology infrastructure in order to supervise
covered persons in a data-driven manner.
EXAMINERS ENCYCLOPEDIA (E2l
Supervision has launched the Examiners Encyclopedia (e2), an internal online resource that
organizes supervisory documentation for reference. The Examiners Encyclopedia includes

guidance and publ ications to support and facilitate the work oftheCFPB's Supervision program,
including links to the CFPB Supervision and Examination Manual. Additional publications
referenced in the tool include:
CFPB Handbooks and Examination Programs;
Regulatory Bulletins (Federal and State);

Federal Register Publications;
Legal Opinions; and
interagency Guidance
COMPLIANCE ANALYSIS SOLUTION
Supervision has also developed the Compliance Analysis Solution (the Solution), an automated
system which supports collection, validation and analysis of loan portfolio data through a
centralized system. The overall objective of the Solution is to analyze 100% of a loan portfolio,
giving examiners the analytical insights necessary to conduct risk-based and targeted
compliance assessments. It also allows secure and standardized data submission to the CFPB,
which enables consistency in the examination process across institutions. Afa ir lending-focused
component to the Solution is also under development.
The first release of the Solution, on October 19, 2012, performed compliance analysis on
mortgage loans, specifically for compliance with the requirements of HOEPA, TllA, and RESPA
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6. Enforcement
The CFPB aims to enforce the consumer protection laws within the Bureau's jurisdiction
consistently and to support consumer-protection effort<; nationwide by investigating potential
violations both independently and in conjunction with other federal and state law enforcement
agencies.
6.1
Conducting Investigations
Since the CFPB's launch, the Office of Enforcement has been conducting research and
investigating potential violations of federal consumer financial laws. Some investigations were
transferred to the Bureau by the prudential regulators and HUD, and the Bureau initiated other
investigations based on potentially problematic practices that Bureau staff identified or
consumers and others have reported. Enforcement has focused its investigative resources on
violations of law that cause the greatest hann to consumers. The investigations currently
underway span the full breadth of the Bureau's enforcement jurisdiction. Further detail about
ongoing investigations will not generally be made public by the Bureau until a public
enforcement action is filed.
6.2 Public Supervisory and Enforcement

Actions
Section 1016(c)(S) of the Dodd-Frank Act requires the Bureau to include in the annual report "a
list, with a brief statement of the issues, of the public supervisory and enforcement actions to
which the Bureau was a party during the preceding year. " The Bureau was a party in nine such
enforcement actions from January 1, 2012 through December 31,2012, detailed as follows:
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In the Matter of: Capital One Bank (U.S.A.),N.A., File No. 2012-CFPB-0001 (July 18,
2012).
The CFPB brought this public enforcement action and obtained an order requiring Capital One
Bank (U.S.A.), NA.to refund approximately $140 million to an estimated hvo million customers
and pay an additional $25 million penalty. The action resulted from a CFPBexamination that
identified deceptive marketing tactics used by Capital One's vendors to pressure or mislead
consumers into paying for "add-on products" such as payment protection and credit monitoring
when they activated their credit cards. The Office of the Comptroller of the Currency (OCC)
brought a coordinated enforcement action against Capital One, which also included restitution
and civil monetary penalties.
In the Matter of: Discover Bank, File No. 2012-CFPB-0005 (September 24,2012)
The CFPBand the Federal Deposit Insurance Corporation (FDIC) jointly determined that
Discover Bank used deceptive telemarketing practices to sell certain credit card add-on products
to cOl15umers. Discover agreed to stop deceptive marketing practices, pay approximately $200
million in restitution to more than 3.5 million customers who purchased credit card add-on
products over the telephone between December 1, 2007 and August 31, 2011, and pay a $14
million civil money penalty.
In the Matters of: American Express Centurion Bank, et al., File Nos. 2012-CFPB-
0002, 2012-CFPB-0003, and 2012-CFPB-0004 (October 1, 201 2).

The CFPB ordered three American Express subsidiaries to refund an estimated $85 million to
approximately 250,000 customers, and, together with the FDIC, the OCC and the Federal
Reserve Board, imposed an additional $27.5 million in civil money penalties. The Utah
Department of Financial lnstitutiol15 (DFI) also took its own enforcement action. The
investigation of American Express began after a routine exam by the FDICand Utah DFI which
was shared with the CFPBafter the CFPB inherited jurisdiction over federal cOl15umer financial
laws in July of 2011. The CFPBand its sister regulators determined that the programs of various
American Express-related companies violated consumer protection laws, including the Card Act,
ECOA, the FCRA, and the prohibition against deceptive practices, at nearly every stage of the
cOl15umer experience, by using deceptive marketing and debt collection practices, unlawfully
discriminating against new account applicants on the basis of age, failing to report col15umer
disputes to cOl15umer reporting agencies, and charging unlawful fees. The fair lending violatiol15
at issue in this matter are discussed in greater detail in the Fair Lending Enforce ment section
below.
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Consumer Financial ProtecnonBureau v. Gordon, etal. (C. D. Cal. No. 12-CV-06147)
(complaint filed July 18, 2012).

This action involves a nationwide mortgage relief scheme in which the CFPB allegE'-" that the
defendants took advantage of financially distrE'-"sed homeowners by promising to help them
obtain loan modifications and charging them an advance fee ranging from $2,500 to $4,500. In
reality, the CFPB believes, the defendants provided consumers with little, if any, meaningful
assistance to modify their mortgages. On July 18, 2012, at the Bureau's request, the U.S. District
Court issued a Temporary Restraining Order, effectively halting the alleged scheme. The
complaint charges that the Defendants violated the Dodd-Frank Act and the Mortgage
Assistance ReliefSelVice:; Rule, recodified as Regulation O. On November 16, 2012, the Court
entered a Preliminary Injunction against the Defendants, finding that the Bureau was likely to
succeed on the merits of its case. On February 1, 2013, the Court entered a Stipulated Final
Judgment and Order for Permanent Injunction and Settlement of Claims as to Defendants
Abraham Michael Pessar, Division One Investment and Loan, Inc., and Processing Division,
LLC.
In re: 3D Resorts-Bluegrass, LLC, (W.D. Ky., Bankruptcy No. 11-41599) (proof ofclaim
filed July 20, 2012).
The CFPB filed a proof of claim in this bankruptcy action based on potential violations of the
Interstate Land SalE'-" Full Disclosure Act and the Dodd-Frank Act of 2010. The potential
violations include a seriE'-" of alleged misrepresentations by a lot seller debtor and others
regarding the registration, marketing, and sale of certain lots on a property known as the Green
Fann Resort.
Consumer Financial Protecnon Bureau v. Jalan, et al. (C.D. Cal. No. 8:12-CV-
02088)(complaint filed December 3, 2012).

This action involves a nationwide mortgage relief scheme that the CFPB alleges took advantage
of financially distressed homeowners. The complaint alleges that the defendants promised to
help those homeowners obtain loan modifications and charged them an advance fee ranging
from $1,000 to $3,000 or more. TheCFPB contends that the defendants provided consumers
with little, if any, meaningful assistance to modify their mortgagE'-". On December 4, 2012, at the
Bureau's request, the U.S. District Court issued a temporary restraining order, effectively halting
the alleged scheme, and the defendants subsequently stipulated to a preliminary injunction that
was issued on December 14, 2012. The complaint charges that the defendants violated the DoddFrank Act and the Mortgage A<lsistance Relief SelVices Rule, recodified as Regulation O.
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Consumer Financial Protection Bureau, et al. v. Payday Loan Debt Solution, Inc.,
etal. (S.D. Fla. 201 2).
The CFPB obtained a stipulated final judgment in federal district court against a nationwide
debt-relief company, Payday Loan Debt Solution, Inc. (PLDS) and its principal, Sanjeet Parvani.
The CFPB brought this action in partnership with the State Attorneys General of New Mexico,
North Carolina, North Dakota and Wisconsin, and with the State of Hawaii Office of Consumer
Protection, based on a CFPBinvestigation. The investigation revealed that PLDS routinely
charged consumers advance fees before attempting to settle their debts. This practice violates
the Telemarketing Sales Rule, the Dodd-FrankAct of 2010, and various state laws. The court
required PLDS to pay a full refund of up to $100,000 for the advance fees, imposed a $5,000
civil penalty, and enjoined PLDS and its principal from engaging in future unlawful conduct.
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477
7. Fair Lending
The eFPB's Office of Fair Lending and Equal Opportunity (Fair Lending) is charged by Congress
with "providing oversight and enforcement of Federal laws intended to ensure fair, equitable,
and nondiscriminatory access to credit for both individuals and commllnit ies~ that are enforced
by the CFPB, including ECOA and HMDA. 42
ECOA 43 prohibits discrimination in mortgage lending and a wide array of other lending,
including auto finance, credit cards, business loans, and unsecured loans. HMDA 44 requires that
specified mortgage lenders annually collect and accurately report mortgage lending data in
order to determine whether institutions are serving the housing needs of their communities, to
aid in targeting public investment, and to identify possible discriminatory lending patterns and
enforce fair lending laws.
In addition, Fair Lending is charged with "coordinating fair lending efforts of the Bureau with
other federal agencies and state regulators, as appropriate, to promote consistent, efficient, and
effective enforcement of federal fair lending laws,,4s and '\vorking with private industry, fa ir
lending, civil rights, consumer and community advocates on the promotion of fair lending
compliance and education.,,46 The Dodd-Frank Act also mandates "annual reports to Congress
42 Dodd-Frank Act, 1013(C)(2)(A).

43 See 15 U.S.c. 1691 et seq.
44 See 12 U.S.C. 2801 et seq.

4S Dodd-Frank Act, 1013(c)(2)(B).
46 Oodd-FrankAct, IOI3{C){2){C).
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on the efforts of the Bureau to fulfill its fa ir lending mandate"47 and transfers to the CFPB
annual reporting responsibilities set forth in ECQA 48 and HftWA.49
Pursuant to the Dodd-Frank Act's requirement that the Bureau report to Congress annually on
its efforts to fulfill its fair lending mission so, the Bureau submitted its Fair Lending Report in
December 2012 in satisfaction of both this requirement and the Bureau's reporting
requirements under ECOAand HMDA. The inaugural Fair Lending Report described the
Bureau's first-year accomplishments in fair lending, which included - among other things establishment of the Office of Fair Lending, commencement of the CFPB's fair lending
supenrision program and completion of various levels of fair lending reviews at dozens ofbank
and nonbank institutions offering a variety of lending products, development of the CFPB's fair
lending enforcement program, and initiation of fair lending investigations.
In this update, we focus on highlights from our fair lending supervision program, a recent fair
lending enforcement action, and interagency coordination activity.
7.1
Fair Lending Supervision
With respect to ECOA, the CFPB has discovered that some institutions have inadequate fai r
lending compliance programs. In order to avoid potential fai r lending compliance issues, every
financial institution should establish fair lending policies, procedures and internal controls
which are tailored to the particular institution's size and operations, in order to ensure that it is
operating in compliance with ECOA and its implementing Regulation B, in all of the financial
institution's relevant lines ofbllsiness. Additionally, CFPB examiners have identified several
institutions with significant error rates in data reported pursuant to HMDA. HMDA data plays a
key role in the work of the CFPB's examination teams and Fair Lending, as well as other
47 Dodd-Frank Act, IOI3(c)(2)(O).
48 See 15 U.S.C. 1691f.

49 See 12 U.S.C. 2807.
SO Dodd-Frank Act, IOI3(C)(2){O).
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regulatory agencies. Lenders that do not accurately report data under HMDA violate the law,
and hinder regulators' and the public's ability to compare mortgage data across the industry in a
meaningful way.
7.2 Fair Lending Enforcement

As discussed in the section on Enforcement above, on October 1, 2012, the CFPB - together with
federal and state partners - announced a public enforcement action against American Express.
The CFPB announced that it had issued orders requiring three American Express subsidiaries
to, among other things, refund an estimated $85 million to approximately 250,000 customers
and pay a civil money penalty of $14.1 million to the CFPB for violations of consumer protection
laws. Fair Lending, working closely with Supervision and Enforcement colleagues within the
Bureau, addressed practices at one subsidiary involving the use of a credit scoring system that
took age into account when evaluating applicants. The CFPB found that the subsidiary,
American Express Centurion Bank, discriminated against applicants on the basis of age because
its credit scoring system did not comply with ECOA and its implementing regulation.
The Consent Order required American Express Centurion Bank to take all action necessary to
eliminate violations of ECOA and ensure full compliance with the law. Specifically, American
Express Centurion Bank will not unlawfully discriminate based on age in credit decisions and
will also be required to certify that all qualified consumers who suffered unlawful age
discrimination have an opportunity to reapply for a card.
7.3 Interagency Fair Lending Coordination

Fair lending supervision and enforcement requires close partnerships and coordination both
among the various divisions and offices within the Bureau, as well as among the Bureau's many
federal and state regulatory and enforcement partners. Recently, recognizing that effective
cooperation is important to protect consumcrs, prevcnt duplication of efforts, and provide
consistent enforcement of federal fa ir lending laws, the CFPB formalized its fair lending
enforcement relationship with the Civil Rights Division of the United States Department of
Justice via an MOU.
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The CFPB has also engaged in a variety of efforts to coordinate with other federal supervisory
and enforcement agencies, and has begun outreach to state agencies. Those efforts include
joining the U.S. Department of Justice, HUD, the Federal Reserve, and the National Association
of Attorneys General as a co-chair of the Federal Financial Fraud Enforcement Task Force's
Non-Discrimination Working Group. The Task Force brings together representatives from law
enforcement agencies, regulatol)' authorities, inspectors general, and state attorneys general to
combat fina ncial fraud. The CFPB also participates in the Federal Interagency Task Force on
Fair Lending, which brings together various federal regulatory agencies 51 to discuss and
coordinate fair lending activities.
The CFPB is committed to working with federal and state partners to ensure that all instances of
unlawful discrimination in lending and unequal access to credit are appropriately addressed.
51 The following agencies also participate in the Federal Interagency Task Force on Fair Lending: HVD, the U.S.
Departmen t of Justire, the OCC, the Federal Reselye, the FDIC, the Federal Housing Finance Agency, the NCVA, and
the FIe.
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8. Building a Great Institution:

Update
The CFPB strives to promote transparency, accountability, and fairness. Built on these values,
the CFPB is better able to make consumer financial markets work for consumers, honest
businesses, and the economy.
8.1
Open Government
Akey mission of the CFPB is to make consumer financial products and services more
transparent in the consumer marketplace. The CFPB strives to lead by example by being
transparent vvith respect to its own activities.
The Bureau's website is its primary vehicle for sharing information. For example, the Bureau
posts the following information on consumerfinance.gov:
Leadership Calendars
The CFPB is committed to letting consumers know the daily schedules of its senior
leadership. The Bureau posts the monthly calendars of its Director and Deputy Director
on its website. To further the usefulness of these calendars, the Bureau provides the
calendars in multiple formats52 on a monthly basis.
Budgl1: Updates
The CFPB has published regular quarterly budget updates on its website, including
financial reports for each quarter of the fiscal year, three fiscal years' worth of funding
52 E.g. inleractirc/web-based, ics file. RSS feed and Adode pdf.
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requests and acknowledgements, and information about the Bureau's Civil Penalty Fund
that was created under the Dodd-Frank Act.
General Reports
The CFPB publishes a variety of reports to document challenges observed in the
consumer financial marketplace, to present empirical findings to policymakers, and to
illustrate progress in specific areas. Recently published reports concern reverse
mortgages, private education loans, an analysis of differences between consumer and
creditor-purchased credit scores, a report on the credit reporting marketplace, the
annual report of the CFPB Student Loan Ombudsman, and a report on student loan
sclVicing and the cost to our men and women in uniform. S3 Additionally, the CFPB
posted a list of depository institutions and depository affiliates of depository institutions
under its supervisory authority. Finally, in certain instances, the Bureau publicizes
petitions made to modify or set aside civil investigative demand actions.
Guidance Updates
From time to time, the CFPB will publish specific materials providing guidance to
industry and members of the public. In 2012, the Bureau provided additional guidance
on its website in the form of a Statement of Intent for sharing information with state
banking and financial sclVice regulators, a bulletin regarding FCRA's streamlined
process requirement for consumers to obtain free annual credit reports, a bulletin
regarding implementation of the remittance rule, a bulletin regarding appeals of
supelVisory matters, a bulletin regarding the marketing of credit card add-on products, a
final policy statement on the publication of credit card complaint data, interagency
guidance on mortgage servicing practice concerning military homeowners with
Permanent Change of Station Orders and a supervisory coordination MOU with the
Federal Reerve Board, FDIC, NCUAand OCC.~ Additionally, the Bureau has posted
information about its Amicus program, the briefs filed in court, and the Information
Quality Guidelines that illustrate how the Bureau strive to ensure and maximize the
quality, objectivity, utility and integrity of the information it disseminates to the public.
53SeeAppendix E for a list of all the reports published in 2012 by the CFPB.
54 All guidance documenlsand MOUs may be found al cOllsumerfinance.gov/guidance/.
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9. Budget
The Bureau is committed to fulfilling its statutory responsibilities and delivering value to
American consumers by being accountable and llsing our resources wisely and carefully.
The CFPB's Operations Division is responsible for coordinating activities related to the
development of the CFPB's annual budget. The Office of the Chief Financial Officer within the
Division has primary responsibility for developing the budget, and works in close partnership
with the Office of Human Capital, the Office of Procurement, the Technology and Innovation
team, and other program offices to develop budget and staffing estimates in consideration of
statutory requirements, performance goals, and priorities of the Bureau. The CFPBDirector
ultimately approves the CFPB budget.
9.1
How the CFPB is Funded
The CFPB is funded principally by transfers from the Board of Governors of the Federal Reserve
System, up to the limits set forth in the Dodd-Frank Act. The Director of the CFPB requests
transfers from the Federal Reserve System in amounts that are reasonably necessary to cany out
the Bureau's mission. Annual funding from the Federal Reserve System is capped at a fixed
percentage of the total 2009 operating expense.<; of the Federal Reserve System, equal to:
10% ofthe.<;e Federal Reserve System expenses (or approximately $498 million) in fiscal
year (FY) 2011;
11%of these expense.<; (or approximately $547.8 million) in FY 2012; and
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12% of these expenses (or approximately $597.6 million) in FY 2013 and each year
thereafter, subject to annual adjustments. 55
As,
of December 31, 2012, the CFPB had requested transfers from the Federal Reserve totaling
$136.2 million to fund CFPB operations and activities for the first quarter of FY 2013. 56 These
funds are held in an account for the Bureau at the Federal Reserve Bank of Nevi York.
Bureau funds that are not funding current needs of the CFPB are invested in Treasury securities.
Earnings from those investments are also deposited into the Bureau's account. 57
If the authorized transfers from the Federal Reserve are not sufficient in FY 2010-2014, the
CFPB has the authority to ask Congress for up to $200 million in additional funds, subject to the
appropriations process. 58 The CFPB did not request an appropriation in FY 2011 or FY 2012 and
does not plan to request one in FY 2013 or FY 2014.
Pursuant to the Dodd-Frank Act, the CFPB is also authorized to collect and retain for specified
purposes civil penalties collected from any person in any judicial or administrative action under
federal consumer financial laws. S9 The CFPB generally is authorized to use these funds for
payments to victims of activities for which civil penalties have been imposed, but may also use
the funds for purposes of consumer education and financial literacy programs under certain
circumstances. The CFPB maintains a separate account for these funds at the Federal Reserve
Bank ofNe\v York.
In the fourth quarter of FY 2012, the CFPB conducted major enforcement actions against Capital
One Bank and Discover, which resulted in the institutions entering into two separate consent
orders. The institutions agreed to pay a total of $32 million in civil monetary penalties to the
CFPB, and also agreed to provide other relief directly to consumers.
SS See DOOd-FrnnkAct, Pub. L No. 1lI-203, Sec. 1017(a)(2).
56 The Bureau posts all funding request letters on its website at consumerfiuanre.gov/budget.
57 See Dodd-Frank Act, Pub. L. No. 111-203, Sec. 1017{h).

58 See id. Sec. I017(e).
59 See id. Sec. I017(d).
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485
In the first quarter of FY 2013, the CFPB also settled enforcement actions against American
Express and PLDS, which resulted in the institutions entering into four separate consent orders.
American Express agreed to pay a total of $14.1million in civil penalties toCFPBand to provide
relief directly to consumers identified in the action. PLDS agreed to pay a total of $5,000 in civil
penalties to CFPB and provide $100,000 in redress for hanned consumers.
9.1.1
Fiscal Year 2013 Spending
As of December 31, 2012, the end of the first quarter ofFY 2013, the CFPBhad spent $85.9
million (including commitments, obligations, and outlays) for FY 2013. The CFPBspent
approximately $45 million on employee compensation and benefits for the 1,073 CFPB
employees who were on-board as of December 15, 2012.
In addition to pa)Toll expenses, the largest obligations for the first quarter of FY 2013 were
related to contractual services. Large obligations of $1 million and over made during the first
quarter ofFY 2013 to both government and non-government vendors included:
$7.5 million to the Department of Treasury for cross-servicing of various human
resource and financial management services, such as core financial accounting,
transaction processing and reporting, travel and payroll;
$3.5 million for maintaining ongoing operations of the CFPB's consumer contact center
and enhancements to the case management database;
$3.5 million for facility operations and maintenance costs for the CFPB's headquarters
building;
$1.5 million for electricity at CFPBheadquarters;
$l.4 million for security services at CFPB headquarters; and
$1.2 million for management and consulting services for the CFPB's Office of Consumer
Response.
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TABLE 4:
BREAKS OUT YEARTO-OATE SPENDING BY EXPENSE CATEGORY
Expense Category
FY 2013 Spending to Date'
Personnel Compensation
535,323,000
8enem Compensation
9,605,000
Travel
2,569,000
TranslXlrtation of Things
15,000
Rents, Communications, Utilities & Misc
3,635,000
Printing and Reproduction
72,000
Other Contractual Services
28,865,000
Suppies & Materials
836,000
Equipment
5,002,000
Total (as of 12131112)
$85,922,000
'Include;; open rommitments for procurements for which a w.ndor has not yet been determined
and funds have not yet been obligated.
TABLE 5: TABlE 9 BREAKS OUT 2013 YEARTOOATESPENDING BY DIVISION/PROGRAM AREA

DIvIsion/Program Area
FY 2013 Spending to Date
Office of the Director
S1 ,231 ,000
Operations
Consumer Education & Ergagement
2,585,000
7,910,000
SuperviSion, Enforcement, Fair Lending
22,857,000
Legal Division
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2,521 ,000
487
External Affairs
1,066,000
Ombudsman
95,000
60
17,866,000
$86,922,000
Centralized Services
9,1.2 Fiscal Year 2012 Spending

In FY 2012, which ended on September 30, 2012, the CFPB incurred $299.76 million in
obligations.61 Approximately $134 million was spent on employee compensation and benefits
for the 970 CFPB employees on-board by September 30, 2012.
In addition to payroll expenses, the largest obligations for FY 2012 were related to other
contractual services, such as administrative services provided by other Federal agencies,
including the Department of Treasury.

As required by the Dodd-Frank Act, the CFPB prepared financial statements for FY 2012. The
n
Government Accountability Office (GAO) rendered an unqualified, or "dean audit opinion on

the CFPB's financial statements. GAO noted no material weaknesses or significant deficiencies
in CFPB's internal controls and cited no instances of noncompliance with laws and regulations.
The CFPB financial statements and GAO's opinion are available in the Financial Report of the
CFPB for FY 2012.
00 Centralized services include the cost of certain administratiw and operational sel'\lces provided centrally to other
Divisions (e.g., building space, utilities, and IT-related equipment and sel'\ices),
61 Budget and spending infonnalion is available at ronsumerfinance.gol'/budget.
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TABLE 6:
BREAKSQUT FINAL FY 2012 SPENDING BY EXPENSE CATEGORY
Expense Category
FY 2012 Spending
Personnel Compensation
S99,464,000
8enem Compensation
34,727,000
Travel
10,117,000
TranslXlrtation of Thir.;Js
166,000
Rents, Communications, Utilities & Misc
1,514,000
Printing and Reproduction
1,693,000
Ott"er Contractual Services
134,933,000
Suppies & Materials
2,556,000
Equipment
14,590,000
Tolal (as of Il30l12)
$299,760,000
TABLE 7: BREAKS OUT FINAL FY 2012 SPENDING BY DIVISIONIPROGRAM AREA
DIvIsion/Program Area
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Office of the Director
S3,948,000
Operations
73,895,000
Consumer Education & Ergagement
15,036,000
24,838,000
Supervision, Enforcement, Fair Lending
83,027,000
legal Division
7,821,000
External Affairs
3,773,000
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FY 2012 Spending
489
Centralized Services
87,422,000
$299,780,000
Some of the Bureau's significant obligations that occurred during F1' 2012 included:
$19.8 million to Treasury for various administrative support services, including
information technology and human resource systems support;
$14.2 million fo r occupancy agreements with other federal agencies;
$10.3 million for project and administrative management, as well as general consulting
selVices, to support the Office of the Chief Information Officer through the end of fY
2013;
$8.4 million to a contractor for the development and operation of the Consumer
Response System;
$7.6 million to the Bureau ofthe Public Debt for cross-servicing of various human
resource and financial management services, such as core financial accounting,
transaction processing and travel;
$6.8 million to an information technology contractor for project management support
selVices;
$4.0 million to a contractor for hosting, cloud infrastructure, and system administration
services; and
$3-9 million to a contractor for human resource support services.
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490
10. Diversity and Excellence

10.1 Recruiting and Hiring
Over the past year, the CFP Bhas pursued a strategic imperative to recruit and hire highly
qualified individuals. These efforts have focused on filling vacancies at its headquarters in
Washington, DC, and in its examiner workforce distributed across the country. The Bureau's
examiners are organized by regions and anchored by key strategic satellite offices in three of the
nation's financial hubs - Chicago, IL; New York, NY; and San Francisco, CA. As of December 15,
2012, there were 1,073 staff on-board and working to carryont the CFPB's mission. These
include approximately 230 highly qualified regulators, researchers, lawyers, and market
practitioners who transferred to the CFPBfrom consumer protection divisions of the prudential
regulators and other federal agencies.
N; the
Bureau continues to grow, the CFPB has implemented a strategic recruiting plan that
enhances formal recruiting efforts62 to ensure a sustainable pipeline of diverse candidates for
occupations across the Bureau. This strategy includes:
Conducting significant and broad outreach at over 60 universities and affinity group
events to introduce potential employees to the mission, vision, and values of the CFPB;
Establishing a flagship jobs website to provide candidates with information about
employment opportunities across CFPB divisions;
Utilizing over 200 existing staff as recruiters to share their experiences with potential
employees;
62 These inclnde utilizing USAJobs and the posting of job annOlln~mellts on the CFPB website at
ronsumerfinance.gov/jobs/.
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491
Using social media to connect with potential employees and spread information about
employment opportunities at the CFPB;
Enlisting senior leadership to host outreach events to attract people to the CFPBas a
~best place to serve";
Creating professional development programs to build a robust pipeline of talent to meet
current and emerging workforce needs, such as the Presidential Management Fellows,
Director's Financial Analysts and Honors Attorney programs, as well as a 51-person
summer intern program;
Partnering with diversity and professional groups such as the Hispanic National Bar
Association and the Partnership for Public SelVice to conduct online and in person
infonnation sessions about applying for careers with the CFPB and other federal
agencies;
Employing a novel strategy of reaching candidates through focused social media and
relevant print and online publications;
Working closely with our colleagues to help prospective employees get a sense for the
CFPB culture and employee experience; and
Working closely with our colleagues in design, technology, and consumer engagement to
develop an employer identity that invites people to learn more about the work of the
CFPB.
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FIGURE8: QUARTERLY GROwrH OF CFPB POSITIONS FILLED THROUGH DECEMBER 15, 2012
'"ww
..9
:!;
FY,1
FY11
ru
FY11
FY'1
00
FY12
FY12
ru
FY12
FY12
00
FY13
FISCAL YEARS 2011-2013
10.2 Staff Education, Training and

Engagement
Since its creation, the CFPB has focused on strong engagement with existing and potential
Bureau staff, successfully utilizing education, training, and engagement programs. A5 the CFPB
matures, it continues to build and offer:
Robust programs that aim to keep its employees current on the latest skills they need to
conduct their work and he sucCf5sful;
Vehicles for full participation in a vibrant culhlre that adheres to the CFPB's values of
Serve, Lead, and Innovate, and that fosters the successful achievement of its mission;
Management training and process support for performance management to provide
employees with clear performance plans and objectives, and meaningful feedback on
their performance; and
Programs and methods to ensure that the CFPBattracts the best, brightest, and most
diverse group possible to carry out its mission.
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493
The CFPB is developing a learning environment tailored to meet the specific needs of the
Bureau's divisions and the individuals within them.
In addition, the Bureau's Office of Human Capital (OHC) is working to identify, cultivate, and
sustain a diverse workforce and inclusive work environment. OHC is committed to a culture that
encourages collaboration and fairness, and leverages diversity throughout the organization so
that all individuals are equipped to Serve, Lead, and Innovate.
10.3 Diversity
Diversity has been a cornerstone of the CFPB's foundation, its strategic workforce planning
programs, and its contracting since its establishment. In January 2012, the Bureau formally
established The Office of Minority and Women Inclusion (OMWl ) to ensure that inclusion
continues to inform its work, and in April 2012 hired the first Director for this office.
The OMWI focuses on developing and refining standards for:
Equal employment opportunity, workforce diversity, and inclusion at all levels of the
Bureau;
Increased participation of minority-owned and women-Qwned businesses in theCFPB's
programs and contracts; and
Assessing the diversity policies and practices of entities that the CFPB regulates.
10.3.1 Diversity in the CFPB's Workforce

As of December 15, 2012, the CFPB's workforce is 48%women and 52%men. Minorities
comprise 34% of the CFPB workforce.
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494
FIGURE9: BUREAU-WIDE GENDER AND MINORITY STATISTICS TO FIRREACOMPARISQNS
48%
Female
Female FIRREA Comparison

FIRREA Comparison
Figure 963 compares CFPB's workforce to the FIRREA community with respect to diversity by
gender, race, and ethnicity,
10.3.2 OMWI 'S Role at the CFPB

OMWI helps all parts ofthe Bureau bring diverse perspectives to their work and promotes
inclusive hiring and contracting practices.
EMPLOYMENT
OMWI is responsible for promoting diverse and inclusive employment practices at the Bureau.
OMWI is collaborating with OHC to develop long-term plans that focus on active participation
at recruitment and outreach events in order to attract a diverse pool of qualified candidates
emphasizing diversity from a wide range of American society.
OMWI is assisting with the development of internal systems and processes that will continually
support the capability to attract applicants and ensure that the CFPB has the benefit of a diverse
and qualified pool of candidates for all job openings. To support this effort, OMWI is developing
63 FIRREA numbeIS as of September 2012. Figure 9 corrq>ares the CFPB 'llith other FIRREA agencies IJ.ith respect to
the percentage of IJ.'OInen and racial and ethnic minorities in the workforce.
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495
strategic partnerships with colleges, universities, professional organizations and affinity groups
from across the country. O~nVI is working with hiring managers at the CFPB to create
internship opportunities and entry-level positions that target diverse groups of students around
the country.
OM\VI is also collaborating with OHC and the Office of Equal Employment Opportunity (OEEO)
to develop baseline metries and reporting systems to monitor and analYle the diversity of
applicants and hires. OMWl is involved in developing the applicant assessment process,
including exploring the use of methods that will enhance the qualifications review process.
OM\VI is working with OHC to ensure that employees and supervisors receive diversity training
to expand awareness, knowledge and cultural competencies that aid in the understanding and
management of a diverse workforce and its value to the CFPB mission.
OM\VI is collaborating with OHC and division heads to promote policies, practices, and
procedures to ensure that all employees are developed to their maximum potential. This is
accomplished through a comprehensive workforce planning strategy centered around training
and developmental opportunities, mentoring programs, rotations, lateral moves, and details
that enhance the skills and key competencies necessary for advancement and success. OM\VI
works closely with OHC, OEEO, and department heads in analYling annual employee survey
results, exit inteniew trends and workforce analyties to detennine retention issues and areas of
opportunity to maintain and grow an inclusive workforce at the CFPB. OMWI also supports
affinity group development for the CFPB's workforce to further foster collaboration and
inclusion within the Bureau.
DI VERSITY AND INCLUSION AT REGULATED ENTITIES
Under the Dodd Frank Act, OMWl is required to create standards for assessing the diversity and
inclusion policies and practices of the entities regulated by the CFPB. OM\VI is coordinating
with fellow OMWI Directors at the FDIC, the Federal Reserve, the NCUA, the oce, and the SEC
to create these standards. The OMWls have met with stakeholders from the banking and finance
community, as well as with advocacy and community organizations to discuss methods to
develop the standards.
EXTERNAL AFFAIRS AND COMMUNICATION
In collaboration with External Affairs, OMWI conducts outreach to consumer groups, advocacy
organizations and other stakeholders to develop strong and productive partnerships. These
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meetings serve as forums to discuss concerns and issues such as those related to minority and
women-owned business contracting opportunities with the Bureau, as well as opportunities
v.'ithin the regulated entities. OMWI and the Procurement Office will continue to develop
productive relationships with the representatives of the communities that we SClVe.
PROCUREMENT
The Procurement Office is currently measuring obligations for certain small business contracts
awarded to minority-owned small disadvantaged businesses and women-owned small
businesses. During FY 2012, the Bureau awarded 27% of contract dollars to small businesses. 64
AI;
shown in Table 8, of the total contract dollars awarded in FY 2012, 9%65 went to small
disadvantaged businesses, with a substantial majority of that 9%(, being awarded to certified
8(a) minority-owned firms. Additionally, 6.5%67 of total contract dollars went to woman-owned
small businesses.
TABLE 8: CONTRACT DOLLARS AWARDED TO SMALL BUSINESS BY TYPE
Obligated dollars'
Small disadv"antaged business
$7 M
Woman-owned small business
$5 M
Service disabled veteran owned small business
$4 M
HubZone small business
$1 M
"Dollars may apply to multiple socio-economiccategories.
64 Approximately $21 million.

(, 85% of contract dollars awarded to small disadvantaged businesses, or approximately $6 million, ",..ere awarded 10
certified 8(a) minority-owned firms.
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Coordinating with OMM, the Procurement Office is developing an external website presence
with a forecast of procurement opportunities. Many small and minority-owned businesses may
find trying to do business with the Federal Government difficult and unclear. In an effort to
increase transparency, both offices are working together to provide a forum for Frequently
Asked Questions, and are partnering with our fellow FIRREA partners in developing a joint
training event on "how to do business with the Federal Government," targeting small, minority
and woman-owned businesses.
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498
APPENDIX A
More about the CFPB

GENERAL INFORMATION:
Email Address: info@con5umerfinance.gov

Phone Number: (202) 435-7000
Mailing Address:
ATIN: Employee Name, Division, and/or Office Number
1700 G Street, NW
CONSUMER RESPONSE:
Hours of Operation: 8 am - 8 pm m
Toll Free Number: (855) 411-CFPB (2372)
Espanol: (855) 411-CFPB (2372)
TIY(fDD: (855) 729-CFPB (2372)
Fax Number: (855) 237-2392
MAILING ADDRESS:

PC Box 4503
Iowa City, Iowa 52244
WHISTLEBLOWERS:
Email: whistleblower@consumerfinance.gov
Toll Free Number: 855-695-7974
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499
PRESS & MEDIA REQUESTS :
Email: prcss@consumerfinance.gov
OFFICE OF LEGISLATIVE AFFAIRS:
Legislative Affa irs: 202-435-7960
.1
CFPB OMBUDSMAN'S OFFICE:
Email: CFl'BOmbudsman@clpb.gov
Webpage: (:onsumerfinance.gov/ombudsman
Toll Free Number: (855) 830-7880
Fax Number: (202) 435-7888
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500
APPENDIX B
Statutory Reporting
Requirements
This Appendix provides a guide to the Bureau's response to the reporting requirements of
Section 1016(c) of the Dodd-Frank Act. The sections of the report identified below respond to
Section 1016(c)'s requirements.
Reporting Requirement
Section
A discussion of the significant problems

faced by consumers in shopping for or
attaining consumer financial products or
services
Consumer Challer.;;le5 in
Ot;(aining Financial Products and
Services - Shopping Cha llenges
36-39
Building a Great Insmution:

Update - Budget;
76-82
Apperdix H - FinarK:ial ard

BlXlget Reports
109-10
A list of sjgn~icant rules and orders

adopted by the Bureau, as well as other
significant i n~iatives conducted by the
Bureau, during the preceding year, and the
plan of the Bureau for rules, orders, or
other initiatives to be undertaken during the
up:::oming period
Apperdix C - Sign~icant Rules,

Orders, and Initiatives
95-100
An analysis of complaints about consumer

financial products or services that the
Bureau has received ard collected in ~s
central database on complaints during the
preceding year
Consumer Challenges in
Obtaining Financial Products ard
Services - Consumer Correrns
12-36
A justification of the Bureau's budget

request for the previous year
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501
A list, w~h a brief statement of the issues,

of the public supervisory and enforcement
actions to wtlich the Bureau was a party
during the ~ecedi ng year
Public Supervisory and

Enforcement Actions
The actions taken regarding rules, orders,

aOO supervisory actions w~h respect 10
covered persons which are I'd: credit
unions or delXlSitory inst~Liioos
Appmjix D - Actions Taken

Regarding RlJes, Orders, aOO
$upeNisory Actions wilh Respect
to Covered Persons VlJhich Are
Not Cred~ Unions or Depository
lnsmutions
An assessment of significant actions by

State attorneys general or State regulators
relating to Federal consumer finarx:ial law
N/Ass
NlA
An analysis of the Bureau's efforts to fulfill

its fair IeOOing mission
Delivering for American

CoOSl..lTlers and Leveling the
Playing Field - Fair Lerding
70-73
An analysis of the Bureau's efforts to

increase workforce and contracting
divers~y consistent with the procedures
established by OMWI
Building a Great Institution:

Update - Diversity and
Excellence
83-90
66-69
101-02
68 The Bureau bas uollearned of any such actions lhal have been filed bel....'CCn January 1, 2012 and December 31,
2012.
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502
APPENDIX C:
Significant Rules, Orders,

and Initiatives"
Section I016(c)(3) requirt5 "a list of significant rules and orders adopted by the Bureau, as well
as other significant initiatives conducted by the Bureau, during the preceding year and the plan
of the Bureau for rules, orders or other initiatives to be undertaken during the upcoming
period. ~
In the past year, the Bureau proposed or adopted the following significant rules and orders and
conducted the following significant initiatives 70 :

Rules (proposed and final) to implement Dodd-Frank Act protections concerning
consumer remittance transfers to foreign countries;
Final rule temporarily delaying the effective date of the CFPB's final rule on remittance
transfers;
Rules to implement Dodd-Frank Act provisions on the following:

D
Cl
Cl
Cl
Ability to Repay/Qualified Mortgages (final rule);

Escrows (final rule);
Appraisal requirements for higher-risk mortgages (interagency) under TILA
(proposed and final rules);
Appraisal requirements under ECOA (proposed and final rules);
69 Links to fina l rules, proposed rules and guidance doruments are available from the CFPB's website, available at:
ronsumerfinance.gov/regulations/.
70 To provide a more complete description of the Burea u's ...."()rk duri ng this period, this Appendix also discusses rules
issued in January 2013. In addi tion, to better infonn the public, this Appendix contains a discussion of a broad range
of rulemakings, orders, and initiatives, which may not be defined as 'significant~ for other purposes.
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503
I:l
High-cost mortgage loans under HOEPA (proposed and final rules);
I:l
Loan originator compensation (proposed and final rules); and
I:l
Mortgage loan servicing (proposed and final rules).
Proposed rule combining certain disclosures that consumers receive under Tl LA and
RES PAin applying for and closing on a mortgage loan;
Final rule delaying the implementation date for certain new mortgage disclosure
requirements in order for those requirements to be implemented with the Bureau's final
rule integrating mortgage disclosures under TILA and RESPA;
Concurrently with issuing the final Abilityto Repay/Qualified Mortgage rule, a proposed
rule proposing amendments to the final rule, including exemptions for certain nonprofit
creditors and certain homeownership stabilization programs, and an additional
definition of a qualified mortgage fo r certain loans made and held in portfolio by small
creditors. The Bureau also sought feedback on whether additional clarification is needed
regarding the inclusion of Joan originator compensation in the points and fees
calculation;
Proposed rule amending the rules implementing the credit card ability to pay provisions
ofTILA to address concerns that the current rule unduly limits the ability of spouses and
partners not working outside the home to obtain credit cards based on the income of the
other spouse or partner;
Proposed rule amending the rules implementing TILA's limits on the total amount of
fees that a credit card issuer may require a consumer to pay during the first year after
account opening;
Final rule defining "larger participants" in the debt collection market;
Final rule defining "larger participants n in the consumer reporting market;
Final rules defining procedures for investigations, rules of practice for adjudication
proceedings;
Final rule regarding confidential treatment of privileged information;
Interim final rule ensuring nondiscrimination on the basis of disability in programs and
activities undertaken by the Bureau;
Interim final rule regarding supplemental ethics regulations for CFPBemployees;
Advance Notice of Proposed Rulemaking seeking comment, data and infonnation about
GPR prepaid cards;
Appointed 25 consumer experts for the CFPB's Consumer Advisot)' Board;
Began accepting complaints on bank products and serviC{'S, private student loans,
consumer loans, and credit reporting;
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504
Continued to expand information sharing with state regulators; information sharing

agreements are now in place with 61 state regulatory agencies in 49 states, the District of
Columbia, and Puerto Rico;
Entered into an MOU formalizing the CFPB's fair lending enforcement relationship \\~th
the Civil Rights Di\~sion of the Deparbnent of Justice;
Entered into an MOU \vith the Fl'C to protect consumers and avoid duplication of
federal law enforcement and regulatory efforts;
Entered into an MOU with the prudential regulators to ensure the coordination of
important aspects of the supenision of insured depository institutions with more than
$10 billion in assets and their affiliates;
In collaboration with the Department of Education, released a report to Congress ,vith
respect to private student loans;
Issued Bulletin on third-party ser.~ce providers to supervised entities;
Issued Bulletin regarding marketing of credit card add-on products;
Issued Bulletin regarding Remittance Rule implementation;
Issued the Bureau's Supervision and Examination Manual, Version 2.0;
Issued Examination Appeals Policy;
Issued examination pl'Oredures for education loans;
Issued Statement of Intent for sharing information with state banking and financial
services regulators;
Launched kk CFPB, an interactive online tool that helps consumers find clear, unbiased
answers to their financial questions;
Launched the Consumer Complaint Database;
Proposed policy to Encourage Trial Disclosure Programs;
Launched an interactive online tool to allow students and families to compare financial
aid offers to better understand future debt burdens and navigate paying for college.
Based on feedback from consumers, institutions of higher education, and other
stakeholders, new features and improvements have been implemented;
Released a compliance bulletin regarding the enforcement of ECOA, and recognizing the
disparate impact doctrine;
Released a report and consumer guide about reverse mortgages ;
Released a report on the difference in ~educationar credit scores sold to consumers and
scores sold to and used by creditors;
Released a white paper describing the credit reporting infrastructure at the three largest
crroit reporting agencies;
Released and tested a draft periodic mortgage statement;
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505
Request for Comment on Payday Lending Hearing Transcript;

Request for Information Regarding Complaints From Private Education Loan
Borrowers;
Request for Infonnation Regarding Consumer Use of Reverse Mortgages;
Request for Information Regarding Credit Card Market;
Request for (nfonnation Regarding lmpacts of Overdraft Programs on Consumers;
Request for Information Regarding Scope, Methods, and Data Sources for Conducting
Study of Pre-Dispute Arbitration Agreements;
RaJuest for Information Regarding Senior Financial Exploitation;
With the U.S. Department of Defense, the FTC, and the National Association of
Attorneys General, developed a database to combat consumer financial fraud directed at
military members, veterans, and their familie'>;
With the FDIC, the Federal Reserve, the OCX:, and the NCUA, released joint guidance to
address mortgage selVicer practices that may pose risks to homeowners who are serving
in the military;
In 2013, the Bureau also plans to propose or adopt the following significant rules and orders,
and conduct the following significant initiatives:
Final rule addressing proposed amendments to the Bureau's Ability to Repay/Qualified
Mortgage rule and Regulation Z (TILA) to exempt certain nonprofit creditors and certain
homeownership stabilization programs and to add an additional definition of a qualified
mortgage for certain loans made and held in portfolio by small creditors. The rule will
also address whether there is a need for additional clarification regarding the inclusion
ofloan originator compensation in the points and fees calculation;
Final rule (proposed in December 2012) amending the CFPB's remittance rule to provide
additional clarity regarding disclosures and error resolution procedures;
Rule finalizing a Bureau proposal amending the regulations implementing TlLA's limits
on the total amount of fees that a credit card issuer may require a consumer to pay
during the first year after account opening;
Rule finalizing a Bureau proposal to amend the regulations implementing the credit card
ability to pay provisions ofTILA to address concerns that the current rule unduly limits
the ability of spouses and partners not working outside the home to obtain credit cards
based on the income of the other spouse or partner;
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506
Rules finalizing the restatement of regulations implementing consumer financial

protection laws transferred from other regulatory agencies to the Bureau by the DoddFrank Act;
Rules concerning the Consumer Financial Civil Penalty Fund, which will establish
procedures that the Bureau will follow when allocating funds in the Civil Penalty Fund to
victims of activities for which civil penalties were imposed under federal consumer
financiallawsj
Rules concerning debt collection, which will contain procedures for the Bureau's
collection of debts owed to the United States;
Continue to finalize integrated disclosures and accompanying rules for mortgage loans
that satisfy the requirements of both TILA and RESPAj
Continue work on possible regulatory streamlining and burden reduction efforts;
Continue work toward a mlemaking to implement the Dodd-Frank Act amendments to
HMDA;
Continue work toward a rulemaking on GPR prepaid cards;

Continued expansion of the Bureau's capacity to handle consumer complaints with
respect to all products and services within its authority;
Enforcement of Nondiscrimination on the Basis of Disability in Programs and Activities
Conducted by the Bureau of Consumer Financial Protection;
Enforcement of Nondiscrimination on the Basis of Disability in Programs Receiving
Financial Assistance from the Bureau;
Issue reports on private student loans and recommendations on best practices
concerning financial advisors who work with older Americans, as directed in the DoddFrank Act;
Issue reports on various aspects of the Bureau's work and operations, including reports
on Consumer Response, Financial Education, Fair Lending, and Human Capital, among
others,71 as directed in the Dodd-Frank Act;
Pilot program to evaluate certain financial education programs in the field;
Procedures for Filing Claims against the Bureau under the Federal Tort Claims Act for
loss of or damage to property or for personal injury or death;
71 SeeAppendix E for reports.
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507
Propose additional rules to further define the scope of the Bureau's nonbank supervision
program; and
Working jointly with the Federal ReselVe Board, rules finalizing a Board proposal
regarding the Expedited Funds Availability Act as implemented by Regulation CC.
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508
APPENDIX D:
Actions Taken Regarding

Rules, Orders, and Supervisory
Actions with Respect to
Covered Persons which are
not Credit Unions or
Depository Institutions
Section 10 16(c)(6) requires a report on ''the actions taken regarding rules, orders and
supervisory actions with respect to covered persons which are not credit unions or deposito!)'
institutions." Be!:weenJanuary 1, 2012 and December 31, 2012, the Bureau has taken the
following actions with respect to such covered persons:
Final rule defining "larger participants~ in the debt collection market72;
Final rule defining "larger participants" in the consumer reporting market 73; and
Proposed rule regarding procedures for supervising nonbanks that pose risks to
consumers. 74
72 https:/Iy,wv.'Jederalregisle.r.gov/a rticies/2012/12/07/2012-29438/defining-larger-partiripants-of-Ihe-ronsumerdebt-rollection -market -correction.

73 bllps:/ /v.'v{w.federalregisler.gav/artides/'1012/07/20/2012-17603ldefining-larger-participants-of-the-consumerreporting-mancel .
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509
In addition to these items, other Bureau rules issued in 2012 apply to both depository
institutions and non-depository institutions.
74 htt ps:!!v.v,w.federalregisler.gav!artides!Z012!OS!2S!2012-12718!proredural-rules-lo-establish-supenisol1'aUlhorily-o\'{!r-certain-nonbank-ro\'ered-l'ersons-based-on.
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SEMI-ANNUAl REPORT OF THE CFPB. MARCH 2013
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510
APPENDIX E
Reports
The CFPH published the following reports from January 1, 2012 through December 31, 2012,
which may be found at consumerfinance.gov/reportsj:

January 3 0 , 2012: Semi-Annual Report of the CFPB;
March 20, 2012: Fair Debt Collection Practices Act;
March 31, 2012: Consumer Response Annual Report;
April 13, 2012: Plain Writing Compliance Report;
June 19, 2012: Consumer Response: ASnapshot of Complaints R6:!cived;
June 28 , 2012.: Reverse Mortgage Report;
July 30,2012.: Semi-Annual Report of the CFPB;
July 31, 2012: Annual Report to the Committee on Appropriations of the House of
Representatives;
August 10, 2012: Final Report of the Small Business Review Panel on CFPB's
Proposals Under Consideration for Mortgage Servicing Rulemaking;

August 29, 2.012: Private Student Loans;
September 2012: AnaiYl'is of Differences beh..reen Consumer and Creditor- Purchased
Credit Scores;
October 10, 2012: Consumer Response: ASnapshot of Complaints Received;
October 16, 2012: Annual Report of the CFPB Student Loan Ombudsman;
October 18, 2012: Thc Next Front? The Student Loan Servicing and the Cost to our
Men and Women in Uniform;

Odober 31, 2012: S II~rvisoty Highlights: Fall 2012;
November 13. 2012: Independent Performance Audit of CFPBOperations and Budget;
November 15, 2012: Financial Report of the CFPB~ Fiscal Year 2012;
December 6, 2012: Fair Lending Report oftheCFPB;
December 7,2012: 2012 CFPBAnnual Employee SUlVey;

December 13, 2012: Key Dimensions and Pr0ct5ses in the U.S. Credit Reporting System:
A review of how the nation's largest credit bureaus manage consumer data; and
December 20, 2012: Growing our Human Capital.
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511
APPENDIX F:
Congressional Testimony
Senior CFPB staff has testified before Congress a total of 29 times in 2011 and 2012, including
on the following 17 occasions between January 1, 2012 and December 31,2012, which may be
found at consumerfinance.gov/speeches:
January 24, 2012: Richard Cordray before the House Oversight and Government
Reform Subcommittee on TARP, Financial Services and Bailouts of Public and Private
Programs;
January 3 1, 2012 : Richard Cordray before the Senatc Banking Committee;
February 15, 2012: Richard Cordray before the House Financial Services
Subcommittee on Oversight and Investigations ;
March 29. 2012: Richard Cordray before the House Financial Services Committee;
April 26, 2012: Camille Susette before the Senatc Homeland Security and
Governmental Affairs Subcommittee on Oversight of Government Management, the
Federal Workforce, and the District of Columbia;
June 6, 2012: Richard Cordray before the Senate Banking Committee;
June 6, 2012: Gail Hillebrand before the House Financial Services Subcommittee on
Financial Institutions and Consumer Credit;

June 20, 2012: Raj Date before the House Financial Services Subcommittee on
Insurance, Housing, and Community Opportunity;

June 26, 2012: Holly Petraeus before the Senate Committee on Banking, Housing and
Urban Affairs;
July 19, 2012: Raj Date before the House Financial Services Subcommittee on
Financial Senrices and Consumer Credit;

July 24, 2012 : Rohit Chopra before the Senate Conunittee on Banking, Housing, and
Urban Affairs;
July 24,20 12 : Richard Cordray before the House Oversight and Government Reform
Subcommittee on TARP, Financial Services, and Bailouts of Public and Private

Programs;
Au!,"USt 1, 2012: Richard Cordray before the House Committee on Small Business;
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512
September 13, 2012: Richard Cordray before the Senate Committee on Banking,
Housing, and Urban Affairs;
September 20, 2012: Richard Cordray before the House Committee on Financial
Sen'ices;
November 15, 2012: Hubert H. ~Sk i p~ Humphrey before the Senate Special
Committee on Aging; and
December 19, 201 2: Corey Stone before the Senate Banking Subcommittee on
Financial Institutions and Consumer Protection.
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513
APPENDIX G
Speeches
Director Richard Cordray or Deputy Director Raj Date spoke at the following public events
between January 1, 2012 and December 31,2012, which may be found at
consumerfinance.gov/speeches:
January 5, 2012: Remarks by Richard Cordray at The Brookings Institution in
Washington, DC;
January 17, 2.012: Remarks by Richard Cordray at FD IC Board of Directors in
Washington, DC;
January 18, 2.012: Remarks by Richard Cordray at U.S. Conference of Mayors in
Washington, DC;
January 19, 2012: Remarks by Richard Cordray at Payday Loan Field Hearing in
Birmingham, AL;
February 15, 2012: Remarks by Richard Cordray at League of United Latin American
Citizens Conference in Washington, DC;

February 22,2012.: Remarks by Richard Cordray at CFPS Roundtable on Overdraft
Practices in New York, NY;
March 6, 2012: Remarks by Richard Cordray at National Association of Attorneys
General in Washington, DC;
March 14, 2012: Remarks by Richard Cordray at Independent Community Bankers of
America National Convention in Nashville, Th';
March 16, 2012: Remarks by Richard Cordray at Society of American Business Editors
and Writers in Indianapolis, IN;
March 19, 2012: Remarks by Richard Cordray at Credit Union National Association
Governmental Affairs Conference in Washington, DC;
March 21, 2012: Remarks by Richard Cordray at Consumer Bankers Association in
Austin, TX;
March 28, 2012: Remarks by Richard Cordray at U.S. Chamber of Commerce in
Washington, DC;
April 10, 2012: Remarks by Richard Cordray at Operation Hope in Washington, DC;
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514
April 11, 2012: Remarks by Richard Cordray on the launch of the Financial Aid
Comparison Shopper in Sioux Falls, SO;
April 18, 2012 : Remarks by Richard Cordray at the National Community Reinvestment
Coalition in Washington, DC;
April 18, 2012 : Remarks by Richard Cordray at Jump$tart in Washington, DC;
April 20, 201 2: Remarks by Raj Date at Greenlining Institute Conference in Los
Angeles, CAj
May 3, 2012: Remarks by Richard Cordray at 2012 Simon New York City Conference in
New York, NY;
May 7, 2012 : Remarks by Raj Date at Mortgage Bankers Association National
Secondary Market Conference in New York, NY;
May 10, 2012 : Remarks by Richard Cordray at the White House Financial Summit in
Washington, DC;
May 11, 2012: Remarks by Richard Cordray at Michigan State University College of Law
Commencement in East lansing, MI;
May 23. 2012 : Remarks by Richard Cordray at CFPB Prepaid Cards Field Hearing in
Durham, NC;
June 5, 2012: Remarks by Richard Cordray at a White House press briefing on student
loan transparency in Washington, DC;
June 11 , 2012: Remarks by Raj Date at Arnerican Bankers Association Conference in
Orlando, FL;
June 14. 20.2: Remarks by Richard Cordray at World Elder Abuse Awareness Day
E\'cnt in Washington, DC;

June 15, 2012: Remarks by Richard Cordray at American Constitution Society
Conference in Washington, DC;
June 21, 2012: Remarks by Richard Cordray at a press conference on Military
Permanent Change of Station (PCS) Guidance for Mortgage Ser\'icers in Washington,
DCJune 27, 2012: Remarks by Richard Cordray on Reverse Mortgages Study in
Washington, DC;
July 9, 2012 : No Mas: Remarks by Richard Cordray to the National Council of La Raza
in Las Vegas, Nevada ;
July 16, 2012: Remarks by Richard Cordray on Credit Reporting at the Credit
Reporting Field Hearing in Detroit, MI;
September 20, 2012: Remarks by Richard Cordray at the Corporation for Enterprise
Development Conference in Washington, DC;
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September 21. 2012: Remarks by Richard Cordray at the Congressional Black Caucus
Foundation in Washington. DC;
September 27. 20J2: Remarks by Richard Cordray at the inaugural Consumer
Advisory Board meeting in Sf. Louis, MO;
October 24. 2012: Remarks by Richard Cordray at the Public Field Hearing on Debt
Collection Practices in Seattle, \VA;
October 25. 2012: Remarks by Richard Cordray at the National Consumer Law Center
Conference in Seattle, WA;
November 14. 2012: Remarks by Richard Cordray on Project Catalyst: Stimulating
Innovation in Financial Products and Services in Mountain Vie','. , CA;
December 5, 2012: Remarks by Richard Cordray at a press conference with Mayor
Rahm Emanuel in Chicago, IL; and
December 13, 2012: Prepared remarks by Richard Cordray on a credit reporting white
paper press call.
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516
APPENDIX H:
Financial and Budget Reports

The CFPS has published the following financial reports from January I, 2012 through December
31,2012, which are all available at consumerfinance.govjhudget:

January 20, 2012: CFO llpdatefor the first quarter of fiscal year 2012;
May 11, 2012: CFO update for the second quarter of fiscal year 2012;
July 27, 2012: CFO update for the third quarteroffiscai yea r 2012;
November 15, 2012: Financial RCjX)rt of the CFPS Fiscal Year 2012; and
December 15, 2012 : CFO Update for the fourth quarter offlScal year 20 12
The CFPBhas published the following Budget Documents, which are all available at
consumerfinance.gov/budget:
Fiscal Year 2013 Budget Justification;
Fiscal Year 2013 Budget in Brief;
Fiscal Year 2012 Congressional Budget Justification; and

Fiscal Year 2012 Budget in Brief.
The CFPB has published the following funding reque<its to the Federal Reserve Board, from
January 1,2012 through December 31, 2012, which are all available at
consumerfinance.gov/budget:
January 6, 2012: Funding Acknowledgement from the Federal Reserve Board;
March 30, 2012: Funding Request to the Federal Reserve Board;
AprilS, 2012: FundingAcknowledgementfrom the Federal Reserve Board;
July 2, 2012: Funding Requcst to the Federal Resen'e Board;
July 9, 2012: Funding Acknowledgement from the Federal Reserve Board;
October 2, 2012: Funding Request to the Federal Resen'e Board; and
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October 18, 2012: Funding Acknowledgement from the Federal Reserve Board.
75
75Addilional quarterly funding rQuests 10 the Federal Reserve Boord and the corresponding funding
acknowledgemenls from Ihe Federal Resel'\'e Board will be made available al ronsumerfinance.gov,ibudgel.
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518
APP ENDIX I:
CFPB Organizational Chart
~ --'-=-=-f -'"~
---=---==--=-
--==--=
L
I
-- ~
--
-"='"-
-="
--
--
=
r ==r
--
.:?E:.
... !::..:::.-
- -~-
-:.-=-
_--=-..
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SEIoIhIoIIIIU'I. REPOIU OFTHE CFPS. MAAO! 2013
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519
APPENDIX J
Defined Terms
ACRONYM
Defined Term
APR
Annual Percentage Rate
ARC
Academic Research Courcil
ATM
Automated Teller Machine
BUREAU
The Consumer Financial Protection Bureau
CAB
Consumer Advisory Board
CARD ACT
The Credit Card Act
CBAC
Community Bank Act....isory Council
CE
The (;FP8's Office of Consumer Engagement
CFPB
The Consumer Financial Protection Bureau
COO
Chief Operating Officer
CUAC
Credit Union Advisory Council
DEP
Delayed Entry Program
DaDDFRANK ACT
The D:ldd-Frank Wall Street Reform and Consumer Protection Act
EeOA
Equal Credit Opportunity Act
EFTA
Electronic Fund Transfer Act
FCRA
Fair Credit Reporting Act
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520
The Federal
FEDERAL RESERVE
BOARD
The Board of Governors of the Federal Reserve System
FHFA
The Federal Housif)J Finarx:e Agerx;y
FIRREA
The Finarx:iallnstitulions Reform, Recovery, and Enforcement Act
FTC
The U.s. Federal Trade Commission
FY
Fiscal year
GAO
Government Accountability Office
GPR
General Purpose Reloadable
HMDA
Home Mortgage Disclosure Act
HOEPA
Home ONnership and Equity Protection Act
HUD
The U.s. Department of Housing aoo Urban Development
MOU
Memoraooum of Understanding
NCUA
The National Credit Union Administration
OA
The CFPB's Office of Older Americans
OCA
The CFPB's Office of Community Affairs
OCC
The U,S. Office of the Com~roller of the Currerx:y
ODEP
The U.S. Department of Lat)x's Office of Disability Em~oyment

Policy
OEED
The CFPB's Office of Equal Employment Opportunity
OFE
The CFPB's Office of Finarx:ial Education
OHC
The CFPB's Office of Human Capital
OMWl
The CFPB's Office of Minority aoo Women Inclusion
OSA
The CFPB's Office of Service Member Affairs
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VerDate Nov 24 2008
Depos~
FDIC
521
PLDS
Payday Loan Debt Solutions
RESPA
Real Estate Settlement Procedures Act
RFI
Request for Information
SAFE ACT
The Secure and Fair Enforcement for Mortgage Ucensing Act
SEC
The U.s. Securities and Exchange Commission
TARP
The T rou~ed Asset Relief Program
TILA
The Truth in Lending Act
TISA
The Truth in Savil"{ls Act
TREASURY
The U,S. Department of the Treasury
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Senate Hearing, 113TH Congress - The Consumer Financial Protection Bureau's Semi-Annual Report To Congress

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Senate Hearing, 113TH Congress - The Consumer Financial Protection Bureau's Semi-Annual Report To Congress

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THE CONSUMER FINANCIAL PROTECTION BUREAUS

SEMI-ANNUAL REPORT TO CONGRESS

VerDate Nov 24 2008

11:00 Jun 14, 2013

L:\HEARINGS 2013\04-23 THE CONSUMER FINANCIAL PROTECTION BUREAU S SEMI-A

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11:00 Jun 14, 2013

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THE CONSUMER FINANCIAL PROTECTION

APRIL 23, 2013

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THE CONSUMER FINANCIAL PROTECTION

APRIL 23, 2013

U.S. GOVERNMENT PRINTING OFFICE

For sale by the Superintendent of Documents, U.S. Government Printing Office

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COMMITTEE ON BANKING, HOUSING, AND URBAN AFFAIRS

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Opening statement of Chairman Johnson .............................................................

Semi-Annual Report of the Consumer Financial Protection Bureau ..................

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THE CONSUMER FINANCIAL PROTECTION BUREAUS SEMI-ANNUAL REPORT TO CONGRESS

OPENING STATEMENT OF CHAIRMAN TIM JOHNSON

Chairman JOHNSON. Good morning. I call this hearing to order.

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Mr. CORDRAY. Thank you, Mr. Chairman, Ranking Member

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