The Consumer Financial Protection Bureau (CFPB) recently added two new disclosures and an attestation requirement to the CFPB portal through which consumers may submit complaints about a financial product or service. The recent additions are under the heading “Credit and consumer reporting complaint notice” and appear to be limited to complaints against consumer reporting agencies (CRAs) regarding inaccurate or incomplete information on a consumer report.
The changes follow a notice and request for comment issued by the CFPB on November 28, 2025, seeking input on the Consumer Response Intake Form, through which consumers can submit complaints, inquiries and feedback to the CFPB on products and services over which the agency has jurisdiction. In the request for comment, the CFPB sought input on whether the collection of information is necessary, ways to enhance the quality and clarity of the information collected, and ways to minimize the burden of collecting information. The CFPB received three comments, all from industry trade associations.
What’s changed?
The CFPB added new disclosures and an attestation requirement for those submitting consumer credit report complaints through the complaint portal. Before filing a complaint, consumers now receive two disclosures informing them that they:
- Are legally required to first dispute inaccurate or incomplete information on their credit report with the CRA.
- May not file their complaint if either they have not submitted their dispute to a CRA more than 45 days ago – the maximum amount of time a CRA has to investigate and resolve a dispute under the Fair Credit Reporting Act – or the dispute is still pending.
Otherwise, the CFPB states it may not respond to or may stop processing the complaint.
The complaint portal also now requires consumers, prior to accessing the Consumer Response Intake Form, to attest both to the truthfulness of the information provided and that they have previously disputed their claim with a CRA.
Looking ahead
The new disclosures on the complaint portal are coming at a time when the number of consumer complaints have reached a record high – including nearly five million complaints filed last year regarding credit reporting and personal consumer reports, according to the CFPB’s Consumer Complaint Database.
The changes to the complaint portal align with recent suggestions from industry trade groups to update the intake system, curb alleged exploitation by bots and credit repair firms, and help ensure only legitimate complaints make it through the database. In one comment letter, an industry trade group suggested that the CFPB place “a prominent notice at the beginning of the complaint process,” which largely tracks the new notice added to the CFPB’s portal. Industry trade groups also recommended establishing internet protocol (IP) monitoring or restrictions on using the same IP address to submit complaints, implementing multifactor authentication to submit complaints and implementing additional identification verification requirements.
Meanwhile, consumer-focused trade groups are scrutinizing these and any potential new changes. For example, one consumer group published a statement raising concerns that blocking the same IP address from being used to submit complaints could mean that citizens would not be able to use certain free resources or public devices (e.g., library computers) to submit complaints.
We will continue monitoring industry developments and additional changes to the complaint portal.