The Clearing House Association submitted a joint comment letter with the ABA to the CFPB Implementation Team in response to a proposed intake form for consumer “complaints, questions, and other information” about financial products or services. The letter (i) notes that in order to establish a robust and effective consumer complaint and inquiry process, a more engaging and facilitative process is necessary than a Paperwork Reduction Act notice and comment; (ii) suggests that separate intake forms be used for consumer complaints versus general consumer inquiries or comments, and (iii) urges the implementation team to focus first on getting a workable consumer complaint intake process in place by July before considering intake forms and processes for the collection of general consumer inquiries and comments.