The Flawed, Company-Centric Design of the Consumer Financial Protection Bureau (CFPB) Complaint Process

1. Consumer Financial Protection bureau (CFPB) CONSUMER COMPLAINT PROCESS “THE FLAWED, COMPANY-CENTRIC DESIGN OF THE CFPB COMPLAINT PROCESS, PROTECTS ‘THE COMPANY’ RATHER THAN "THE CONSUMER”; AND THOUGH, CFPB TAKE NO ACTIVE ROLE IN THE ACTUAL CFPB COMPLAINT ADJUDICATION PROCESS, IT EAGERLY RUBBER-STAMP’S, AND TAKES EXCLUSIVE CREDIT FOR “THE COMPANY” ARBITRATION RESPONSES, WITHOUT FIRST REVIEWING THEM TO ENSURE THAT THEY DO NOT VIOLATE THE FINANCIAL-RELATED, CONSUMER-PROTECTION LAWS, ACTS, AND REGULATIONS; FOR WHICH CFPB WAS CREATED BY THE DODD-FRANK FEDERAL LEGISLATION TO ENFORCE.” To view the full versions of this Interactive-WebShow presentation, please click following link; then click save and open: http://www.cfpbcomplaintmonitor.org/CFPB_Complaint_Process_(Web).ppsx Additionally, printable-PDF copies of this presentation can be found at the following links: Executive Summary: http://www.cfpbcomplaintmonitor.org/Executive-Summary_CFPB_Complaint_Process_(Web).pdf Complete Presentation: http://www.cfpbcomplaintmonitor.org/CFPB_Complaint_Process_(Web).pdf "THE COMPANY" ALWAYS WIN!

2. THE COMPANY-CENTRIC DESIGN OF THE Consumer Financial protection bureau (CFPB) COMPLAINT PROCESS, PROTECTS “THE COMPANY” RATHER THAN "THE CONSUMER”! THE RIGHTS FOR FAIR AND IMPARTIAL ARBITRATION OF ONSUMER’S FINANCIAL-ORIENTED COMPLAINTS, AGAINST FINANCIAL SERVICES INSTITUTIONS, INCLUDING NATIONAL BANKS, HOME MORTGAGE LENDERS, CREDIT REPORTING/MONTIOTING SERVICES, CONSUMER CREDIT SERVICES, PAY-DAY LENDERS, AND OTHERS; WERE ENACTED INTO LAW BY THE US CONGRESS IN 2011 WITH THE PASSAGE OF THE DODD-FRANK WALL STREET REFORM AND CONSUMER PROTECTION ACT*. * Two of the most important consumer protection directives of the Dodd-Frank Wall Street Reform and Consumer Protection Act are not being enforced by the Consumer Financial Protection Bureau (CFPB). "THE COMPANY" ALWAYS WIN!

3. THE COMPANY-CENTRIC DESIGN OF THE Consumer Financial protection bureau (CFPB) COMPLAINT PROCESS, PROTECTS “THE COMPANY” RATHER THAN "THE CONSUMER”! CFPB HAS RELINQUISHED ITS ARBITRATION RESPONSIBILITIES, AS DEFINED UNDER THE DODD-FRANK ACT, AND ALLOWS “THE COMPANY” TO ASSUME ROLES OF: JUDGE, JURY, AND APPELLATE FOR CONSUMER COMPLAINTS FILED VIA THE CFPB COMPLAINT PROCESS. PREDICTABLY, COMPANY” NOW WINS MORE THAN EIGHTY-THREE PERCENT OF ALL NON-MORTGAGE COMPLAINTS; AND LARGE MORTGAGE LENDERS, AND/OR SERVICERS, WIN MORE THAN NINETY-TWO PERCENT OF ITS MORTGAGE COMPLAINTS. BETWEEN DECEMBER 2012 AND MARCH 2017, CFPB COMPLAINT PROCESS INCLUDED A FANTOM COMPLAINT DISPUTE PROCESS THAT SUPPOSINGLY ALLOWED CONSUMERS TO DISPUTE CLOSE RESPONSES FROM "THE. HOWEVER, STARTING IN APRIL 2017, THIS “SHAM” DISPUTE OPTION WAS DISCONTINUED, ALL CLOSED RESPONSES FROM “THE COMPANY” ARE FINAL. FURTHERMORE, SIMILAR (OR IDENTICAL) COMPLAINTS, CANNOT BE RE-FILED, WITH THE CFPB, OR ANY OTHER FEDERAL OR STATE CONSUMERCOMPLAINT AGENCY. THE CFPB APPROVAL OF THE COMPANY’S INITIAL CLOSED RESPONSE IS THE PROVERBIAL “KISS OF DEATH” TO THE CONSUMER COMPLAINT BECAUSE HENCEFORTH, IT CAN THEN BE SITED BY “THE COMPANY” AS THE LEGAL BASIS FOR NOT REOPENING THE CONSUMER COMPLAINT. "THE COMPANY" ALWAYS WIN!

4. THE COMPANY-CENTRIC DESIGN OF THE Consumer Financial protection bureau (CFPB) COMPLAINT PROCESS, PROTECTS “THE COMPANY” RATHER THAN "THE CONSUMER”! “The Company ALWAYS WINS” CFPB COMPLAINTS FILED AGAINST IT BY CONSUMERS, BECAUSE IT Controls the complete CFPB Complaint adjudication PROCESS, INCLUDING REVIEWING, Arbitrating, AND CLOSING consumer COMPLAINTS WITHOUT PUBLICLY-SHARING The legal, moral, or ethical justification for its RULINGS; AND EQUALLY-appalling, there ARE NO FORMAL, DOCUMENTED CFPB Reviews OF: CONSUMER COMPLAINTS SUBMITTED TO CFPB. THE COMPANY’S UNILATERAL, COMPLAINT ADJUTICATION PROCESS. THE Company’s “Wizard of Oz” type RESPONSE TO CONSUMERS. THE Company’s complaint-closing RESPONSE TO cfpb. Indefensibly: IN APRIL 2017, CFPB DISCONTINUED IT’S “BOGUS” COMPLAINT DISPUTE PROCESS*, AND REPLACED IT WITH, AN EVEN MORE IRRELEVANT, NONSENSICAL PROCESS, REFERRED TO AS “THE CONSUMER FEEDBACK PROCESS”. This subterfuge IS INTENDED TO DECEIVE AMERICAN CONSUMERS INTO BELEIVING THAT “CFPB IS ON THEIR SIDE”, WHEN IT IS ACTUALLY ON THE SIDE OF “The Company”. * CFPB deceived consumers by promising that it would “investigate their disputed complaints”, even though the CFPB FOIA Office, found that no formal investigations were ever conducted. "THE COMPANY" ALWAYS WIN!

5. THE COMPANY-CENTRIC DESIGN OF THE Consumer Financial protection bureau (CFPB) COMPLAINT PROCESS, PROTECTS “THE COMPANY” RATHER THAN "THE CONSUMER”! SELF-FULFILLING PROPHECY: WHY “THE COMPANY” ALWAYS WIN! BOTH THE CFPB COMPLAINT PROCESS, AND ITS TIGHTLY-COUPLED CFPB COMPLAINT DATABASE, ARE CURRENTLY SUPPORTED BY ONE OF THE PRE-EMINENT CUSTOMER RELATIONSHIP MANAGEMENT (CRM) VENDORS, AND THIS VENDOR’S INDUSTRY-LEADING CRM PLATFORMS AND METHODOLOGIES ALLOWS THEM TO MANAGE BOTH SIDES OF THE CFPB CONSUMER COMPLAINT PROCESS. THE END RESULTS OF THIS INCESTIOUS-TYPE RELATIONSHIP: 1.) IS THAT BECAUSE THIS VENDOR’S PRIMARY MOTIVATION IS TO SELL CLOUD CRM PRODUCTS TO COMPANIES; AND 2.) VIA THE “CFPB COMPANY PORTAL”, THEY CONTROL THE COMPLETE CFPB COMPLAINT PROCESS: “THE COMPANY” ALWAYS WIN! GIVEN THE CHOICE BETWEEN A “CONSUMER-CENTRIC DESIGN”, AND A “COMPANY-CENTRIC DESIGN”, IT IS UNDER-STANDABLE WHY THE CURRENT COMPANY-CENTRIC COMPLAINT PROCESS WORKS AS IT DOES. "THE COMPANY" ALWAYS WIN!

6. THE COMPANY-CENTRIC DESIGN OF THE Consumer Financial protection bureau (CFPB) COMPLAINT PROCESS, PROTECTS “THE COMPANY” RATHER THAN "THE CONSUMER”! SELF-FULFILLING PROPHECY: “THE COMPANY” ALWAYS WIN! (CONTINUED) THE POOR, AMATEURISH, OR PURPOSELY- DECEITFUL, DESIGN OF THE CFPB COMPLAINT DATABASE RENDERS IT AS VIRTUALLY-WORTHLESS AS THE UNDERPINNING OF THE CFPB COMPLAINT PROCESS. IT IS MISSING CRITICALLY-IMPORTANT DATA FIELDS THAT WOULD DRAMATICALLY-IMPROVE AND/OR FACILITATE THE ANALYTICAL CAPABILITIES OF THE CFPB COMPLAINT PROCESS. THESE IMPORTANT-MISSING DATA FIELDS INCLUDE: DATE OF COMPLAINT INCIDENT, DEMOGRAPHICS OF CONSUMER FILING COMPLAINT, DATE CFPB REVIEWED COMPLAINT, DATE RESPONSE RECEIVED FROM “THE COMPANY”, REFERRING AGENCY, AND FINAL DISPOSITION OF COMPLAINT. VIRTUALLY ALL OF THESE MISSING, OR ILL-DEFINED, DATABASE FIELDS, MAKES IT HARDER;AND, IN SOME INSTANCES, IMPOSSIBLE USE ANALYTICS TO MEASURE THE PERFORMANCE, EFFICIENCY, AND EFFECTIVES OF THE CFPB COMPLAINT PROCESS. "THE COMPANY" ALWAYS WIN!

7. THE COMPANY-CENTRIC DESIGN OF THE Consumer Financial protection bureau (CFPB) COMPLAINT PROCESS, PROTECTS “THE COMPANY” RATHER THAN "THE CONSUMER”! TOP-10 DESIGN FLAWS IN THE CFPB COMPLAINT PROCESS DESIGN FLAW ONE ‒ DATE OF COMPLAINT Allegation NOT recorded in CONSUMER PORTAL OR CDESIGN FLAWS IN THE CFPB COMPLAINT PROCESS FPB COMPLAINT database, MAKING IT IMPOSSIBLE TO CATEGORIZE COMPLAINTS BY DATE. DESIGN FLAW TWO ‒ NO IDENTIFIABLE RACIAL, ETHNIC, SEX, OR AGE Discrimination COMPLAINTs FILED by cfpb AGAINST “the COMPANY” in more than seven years. DESIGN FLAW THREE ‒ THE CFPB RUBBER-STAMP Approval of company response IS THE PROVERBIAL “KISS-OF-DEATH” FOR CONSUMER complaints, BECAUSE THEY CANNOT BE RE-FILED WITH CFPB OR OTHER GOVERNMENT AGENCIES. DESIGN FLAW FOUR ‒ cfpB COMPANY Portal provide “the company” with an unfair, INSURMOUNTABLE advantage OVER THE CONSUMER. DESIGN FLAW FIVE ‒ “THE CompanY” has “no Fear” of THE cfpb CONSUMER PROCESS BECAUSE their closed RESPONSES are never reviewed BY CFPB, AND THERE IS NO DISPUTE PROCESS. DESIGN FLAW SIX ‒ cfpb DESIGN FLAWS IN THE CFPB COMPLAINT PROCESS “LIED TO Consumers” regarding THE potential OF A DIFFERENT appellate outcome VIA “A NON-EXISTANT complaint Dispute process”. "THE COMPANY" ALWAYS WIN!

8. THE COMPANY-CENTRIC DESIGN OF THE Consumer Financial protection bureau (CFPB) COMPLAINT PROCESS, PROTECTS “THE COMPANY” RATHER THAN "THE CONSUMER”! TOP-10 DESIGN FLAWS IN THE CFPB COMPLAINT PROCESS (Continued) DESIGN FLAW SEVEN ‒ THE COMPANY-CENTRIC COMPLAINT ADJUDICATION PROCESS, UNFAIRLY DISCRIMINATES AGAINST THE “HAVE-NOT” VERSUS THE “HAVES” SEGMENT OF CONSUMERS. DESIGN FLAW EIGHT ‒ CONSUMER COMPLAINTS FILED WITH OTHER FEDERAL OR STATE CONSUMER AGENCIES, AND REFERRED TO cfpb are not tracked, and the referring agency is not informed of “the Company” Adjudication response. Federal and state consumer complaint/consumer protection Agencies are prohibited from assuming jurisdiction of financially-oriented consumer complaints even if non-financial acts, laws, or regulations within their jurisdiction are included in the complaint. "THE COMPANY" ALWAYS WIN!

9. THE COMPANY-CENTRIC DESIGN OF THE Consumer Financial protection bureau (CFPB) COMPLAINT PROCESS, PROTECTS “THE COMPANY” RATHER THAN "THE CONSUMER”! ILLUSTRATIVE: CFPB Complaint Process designers included several dates in the Consumer Portal and CFPB Database, including: a.) Date complaint submitted, b.) Date complaint sent to “The Company”, c.) Date “The Company” responded, d.) Date upon which the complaint was closed, and e.) Date consumer feedback provided. However, these designers neglected to include the most important of all dates, i.e., “the date upon which the alleged incident occurred”; and, without this “point-in-time” reference, it is impossible for consumers, regulators, and other “interest-parties” to utilize readily-available analytic tools to detect, and analyze aberrations, patterns, and other signs of fraudulent and/or criminal behaviors by financial services companies, and/or National Banks. DESIGN FLAW ONE ‒ NO DATE OF COMPLAINT Allegation recorded in CONSUMER PORTAL OR CFPB COMPLAINT database: The design of the cfpb complaint database IS predicated on the premise, that each complaint record in the database contains A snapshot of THE consumer complaint, extending from the date that the incident upon which the complaint IS based occurred; until the complaint is formally closed by “the company”, with the concurrence of CFPB. "THE COMPANY" ALWAYS WIN!

10. THE COMPANY-CENTRIC DESIGN OF THE Consumer Financial protection bureau (CFPB) COMPLAINT PROCESS, PROTECTS “THE COMPANY” RATHER THAN "THE CONSUMER”! DESIGN FLAW TWO ‒ NO Discrimination COMPLAINTs FILED by cfpb AGAINST “the COMPANY” in more than seven years. the CFPB Complaint PROCESS is PREDICATED on the premise that consumer complaints can be defined by a finite number of products and sub-products; and, COMPLAINT ALLEGEGATION(S) IN EACH COMPLAINT CAN BE DEFINED BY ONE (or More) issues. However, EXISTING CFPB product OR ISSUES, DO NOT INCLUDE DEMOGRAPHIC IDENTIFIERS SUCH AS: race, ethnicity, AGE, RILIGIOUS, OR gender ; THUS BETWEEN January 2011 and May 2017, it was theoretically-Impossible for Consumers to file discrimination-related COMPLAINTS, via the CFPB COMPLAINT PROCESS. ILLUSTRATIVE: All complaints are assigned an Issue (and an optional sub issue) by a CFPB Reviewer; however, the designers of the CFPB Complaint Process, did not define discrimination type issues (or reserve a customary “Other Issue”), that could be used by the reviewer for undefined issues, such as racial, gender, age, or religious discrimination. The omission of discriminatory issues from the CFPB Complaint Process was a conscience decision, approved by the then Executive Director of CFPB. Click the following link to view this policy directive: https://files.consumerfinance.gov/f/documents/201704_cfpb_consumer_complaint_form_product_and_issue_options.pdf "THE COMPANY" ALWAYS WIN!

11. THE COMPANY-CENTRIC DESIGN OF THE Consumer Financial protection bureau (CFPB) COMPLAINT PROCESS, PROTECTS “THE COMPANY” RATHER THAN "THE CONSUMER”! DESIGN FLAW THREE ‒ CFPB RUBBER-STAMP Approval of company response IS “KISS-OF-DEATH” FOR CONSUMER complaint: THE DECEMBER 2011 TO APRIL 2017, CFPB COMPLAINT PROCESS SHOWS THAT CFPB ALLOWED “The Company” TO ASSUME THE ROLES OF “JUDGE”, AND “Jury”; and IN APRIL 2017, WHEN The only VESTIGE OF AN “dispute/Appeal option” available to the Consumer, was ELIMINATED BY CFPB; and addition to being the “Judge” And “jury”, “THE COMPANY” also assumed the appellate role within The cfpb complaint process. As this implies, since May 2017, Cfpb has had no active role in the cfpb complaint process. ILLUSTRATIVE: During this seven-year period: CFPB has taken the credit for the resolution of hundreds of thousands of complaints submitted by consumers, via the CFPB complaint process. Expediently, cfpb failed to mention that its role was that of an electronic conduit, between the consumer and "The Company”; and was not actively involved in the adjudication of any of these CFPB complaints; and that it did not provide consumers an actionable dispute/appeal process for aforementioned complaints, in which they blindly, “rubber-stamped” the adjudication decisions of “The Company". "THE COMPANY" ALWAYS WIN!

12. THE COMPANY-CENTRIC DESIGN OF THE Consumer Financial protection bureau (CFPB) COMPLAINT PROCESS, PROTECTS “THE COMPANY” RATHER THAN "THE CONSUMER”! DESIGN FLAW FOUR ‒ THE cfpb’s downloadable CONSUMER PORTAl/WEB APPLICATION (app) provides “the company” with a UNSURMOUNTABLE-OMPETITIVE advantage OVER CONSUMERS: ALTHOUGH NOT BY DEFITION A DESIGN FLAW, THE ENHANCED FUNCTIONALITY CONTAINED IN THE WEB-BASED COMPANY PORTAL, IS ORDERS OF MAGNITUDE GREATER THAN THAT CONTAINED IN EITHER THE WEB-BASED CONSUMER PORTAL, OR THE MANUAL PROCESSES USED BY CFPB CONSUMER RESPONSE DEPARTMENT TO CREATE CONSUMER COMPLAINTS FROM EMAIL, PHONE, FAX, MAIL OR REFERRALS. THE MANUAL PROCESSES PERFORMED BY THIS DEPARTMENT CONSIST OF TRANSCRIBING, COPYING, AND CUTTING & PASTING COMPLAINT DATA INTO THE CONSUMER PORTAL. AFTER THE CONSUMER PORTAL IS FORMATED PROPERLY, THE COMPLAINT RESPONSE DEPARTMENT ASSIGNS IT TO ONE OF THE 12 PRODUCT CODES; AND THEN ASSIGNS ONE OF THE 96 ISSUES. THE CONSUMER COMPLAINT IS THEN PLACED ON THE COMPANY PORTAL; AFTERWHICH, CFPB IS THEN OUT OF THE “CONSUMER COMPLAINT ARBITRATION LOOP”. ILLUSTRATIVE: From the company’s perspective, the design objective of “minimizing the burden of companies” was more than exceeded, because in addition to allowing “The Company” to receive consumer complaints from CFPB, and sending adjudication responses to these complaints back to CFPB and the consumer; it also removed many of the manual activities involving in reviewing, researching, and arbitrating consumer complaints. This greatly reduced, and in some instances, eliminated many of the tasks required by “The Company” to arbitrate consumer allegations of transgressions and/or misdemeanors, that may have occurred months, or even, years earlier. "THE COMPANY" ALWAYS WIN!

13. THE COMPANY-CENTRIC DESIGN OF THE Consumer Financial protection bureau (CFPB) COMPLAINT PROCESS, PROTECTS “THE COMPANY” RATHER THAN "THE CONSUMER”! ILLUSTRATIVE: During this seven-year period, CFPB has taken “the credit” for hundreds of thousands of complaints submitted by consumers, using this CFPB Complaint Process; but because they did not, a.) review consumer complaints before they were submitted to “The Company”, b.) review “The Company” responses sent to CFPB before closing the consumer complaint; or c.) have an actionable dispute and/or appeal process; CFPB was never able to “categorize consumer complaints by company” to determine if , a given complaint was a single, isolated complaint; or was one of a series of dozens, (or even hundreds) of similar complaints against the same financial services institution; or a national bank. The current CFPB website does not have the name of a single offending company; even though some refuse to acknowledge CFPB filed complaints in a timely manner, and other have never responded to CFPB. DESIGN FLAW FIVE ‒ LARGE Companies have “no Fear” of the cfpb CONSUMER PROCESS BECAUSE their closed responses are never CHALLENGED BY CFPB: Between DECEMBER 2011 AND APRIL 2017, MORE THAN EIGHT THOUSAND COMPLAINTS ALLEGING FRAUD, IDENTY THETH, AND OTHER CRIMES; YET, DURING THIS PERIOD ONLY TWO COMPLAINTS WERE REFERRED TO CFPB’s INTERNAL ENFORCEMENT UNIT, AND NO COMPLAINTS were referred TO THE DOJ OR OTHER ENFORCEMENT Agencies. "THE COMPANY" ALWAYS WIN!

14. THE COMPANY-CENTRIC DESIGN OF THE Consumer Financial protection bureau (CFPB) COMPLAINT PROCESS, PROTECTS “THE COMPANY” RATHER THAN "THE CONSUMER”! ILLUSTRATIVE: The CFPB Complaint Database shows that between 2012 and 2017, 283,751 CFPB consumer complaints were filed for products such as credit reporting, debt collection, money transfer, payday loan, and prepaid card; and only 4,588 (1.62%) of these complaints were “Closed with Monetary Relief" by “The Company"; during the same period, 38, 786 of 218,968 products such as bank account and service, consumer loan, credit card, other financial service, and student loan, were closed by “The Company”, but 17.71% of these complaints received monetary relief. The 16.09% disparity between these two product segments indicates that there was (and still is) a clear distinction between how "the haves" and "the have-not" consumer segments are served (or not served) by the CFPB Complaint Process. (209,453 CFPB Mortgage Complaints; which fall within both “have” and have-nots” segments, had an annual “Closed with Monetary Relief” response-rate of only 2.98%.) CFPB DESIGN FLAW SIX ‒ DISPARITIES BETWEEN THE ADJUDICATION OF “HAVES VERSUS HAVE-NOTS” COMPLAINTS FILED VIA THE CFPB COMPLAINT PROCESS: ONE OF THE KEY OBJECTIVES OF THE CONSUMER PROTECTION PORTION OF THE DODD-FRANK ACT WAS TO PROVIDE AN ALTERNATIVE FOR THE SEGMENT OF AMERICAN CONSUMERS WHO Do NOT THE FINANCIAL RESOURCES TO Pursue Remedies TO THEIR FINANCIAL-RLEATED COMPLAINT S VIA A PRIVATE Attorney (OR “THE Courts”); This segment, which is referred to as the “have-nots” in this document, is composed of poor, elderly, minorities, and other economically-disadvantagedonsumers. The Cfpb database shows that complaints filed by the “HAVE-NOTS” segment of consumers, Do not receive the same percentage of “CLOSED WITH MONETARY Relief” Responses from “the Company”, as the “HAVE” SEGMENT OF CONSUMERS. "THE COMPANY" ALWAYS WIN!

15. THE COMPANY-CENTRIC DESIGN OF THE Consumer Financial protection bureau (CFPB) COMPLAINT PROCESS, PROTECTS “THE COMPANY” RATHER THAN "THE CONSUMER”! CFPB DESIGN FLAW Seven ‒ cfpb misled Consumer regarding the Potential appellate outcome of the complaint Dispute process: In 2011, When CFPB WAS GIVEN JURISDICTION OVER financial-related consumer complaints, the dispute process was an documented element of the CFPB COMPLAINT PROCESS BETWEEN DECEMBER 2011 THRU APRIL 2017, During this period, responses to 145,150 OF THE 743,427 COMPLAINTS FILED VIA THE cfpb complaint process were disputed; and cfpb promised consumers that their disputes would be “formally investigated”. Unfortunately, None of these promised investigations were conducted by cfpb, and DISPUTED responses from “The Company” WENT UNCHALLENGED. ILLUSTRATIVE: Even more appalling, from the consumer’s point of view, is that from December 2011 to March 2017, 12,081 complaints with identity theft, fraud, and embezzlement complaints issues, and 101,427 complaints with criminal/fraud sub-issues filed with CFPB; and 16.6% of the responses complaint with criminal-type issues, and 17.1% of the responses with criminal-type sub-issues were disputed by consumers. However, as we now know, there was no actionable dispute process in place during this period, and it is likely that no further reviews of these disputed complaints was done by CFPB or “The Company”. (Click here to see more details regarding these issues and sub-issues.) "THE COMPANY" ALWAYS WIN!

16. REASONS WHY THE CFPB COMPLAINT PROCESS DOES NOT WORK • The current CFPB Complaint Process Database does not work because: • CFPB abdicated its fiduciary responsibilities for arbitrating financial-related complaints as defined in the Dodd-Frank Wall Street Reform and Consumer Protection Act; and although CFPB takes no part in the complaint adjudicating process, it takes credit for resolving more than one million consumer complaints. • 76.7% of all complaints received from 2011 through 2017, were either “closed without explanation” or “closed with explanation”; and consumers were awarded “monetary relief “ only 6.7% of the time. • 85.1% of all the 223,135 mortgage complaints, received from 2011 through 2017, were Closed without explanation, or Closed with explanation; consumers filing complaints were only awarded “monetary relief” 2.8% of the time. • CFPB “promised consumers” who disputed the company’s responses, that their disputes would be formally reviewed and/or investigated; yet, none of the 145,150 complaints disputed between 2011 and 2017, were ever investigated by CFPB or referred back to “The Company”. • CFPB blindly rubber-stamps all of “The Company’s” arbitration/closed responses, with first reviewing these responses to ensure that they do not violate federal regulations, e.g., ECOA, HMDA, Civil Rights. • Between 7% and 10% of all consumer complaints include some element of discriminatory practices; yet, in more than seven years, CFPB has never filed a discrimination complaint on behalf of a consumer, and has never referred a complaint to the Civil Rights Division. • Offending companies are never identified; and even some companies who repeatedly refuse to response to CFPB complaints, are not fined, censured, or referred to other federal enforcement agencies. • “The Company” has “No Fear” of the CFPB Complaint Process because the responses to all complaints filed via this process, are routinely rubber-stamped with the CFPB “Kiss of Death” approval, and: a.) cannot be re-filed with either CFPB, or any other federal consumer complaint/consumer protections agency, and b.) similar (or even identical), complaints filed against the same company by other consumers can be arbitrarily-dismissed using the earlier CFPB “Kiss of Death” approval as precedence. "THE COMPANY" ALWAYS WIN!

17. REASONS WHY THE CFPB COMPLAINT PROCESS DOES NOT WORK (Continued) “The Company” can arbitrarily and/or capriciously, request that selected consumer complaints not be published in the CFPB database, without delineating the justification for this action. More than ninety-four percent of public responses to mortgage complaints are not made public, and many large financial services companies and national banks explicitly request specify that “none” of their complaint responses be made public. Consumer complaints submitted to other federal consumer complaint/consumer protection agencies, and then forwarded to CFPB, or not reviewed by CFPB before being forwarded to “The Company”; and this results in even non-financial consumer complaints being “blindly thrown over the wall to CFPB” where they ultimately receive the CFPB “Kiss of Death” approval before being closed forever. There is no way for CFPB to determine if other consumers have filed similar (or even identical) complaints against “The Company” because the design flaws in the CFPB Complaint Process, and the poorly-designed CFPB Complaint Database; however, the Company Portal allows “The Company” to reject (or accept) similar or identical consumer complaints, at its depression. Consumer advocate groups and class-action attorneys are reluctant to accept consumer complaints that were previously filed by CFPB , because of the existence of CFPB’s “kiss-of-death” approval of “The Company” arbitration/closed response. The CFPB Database does not include any consumer-demographic information, so there is no way to determine if the CFPB Complaint Process is being used by all segments of American consumers. The CFPB Database includes “tags” for elderly consumers, service-members, and elderly service-members; but these tags appear to be purely informational, because “The Company” adjudication process does not include any “special processing” for CFPB Complaints with these tags. Consumers filing complaints via the web, are encouraged to append complaint narratives to their CFPB complaints, but it does not appear that “The Company” complaint adjudication process is predicated on any of the ancillary information contained in the consumer narrative. "THE COMPANY" ALWAYS WIN!

18. REASONS WHY THE CFPB COMPLAINT PROCESS DOES NOT WORK (Continued) The CFPB Company Portal was initially-intended to provide an electronic-conduit by which CFPB could quickly and efficiently send consumer complaints to “The Company”, and “The Company” could send its Closed, Closed with explanation, Closed with monetary relief, and Closed without monetary relief responses to back CFPB; however, the CFPB Company Portal has evolved into a full-functions CFPB Application (App) that provides “The Company” with a discernible competitive-advantage over the Consumer Portal, including a complaint-archival database and a one-button complaint response. The ubiquitous, one size fits all design of the CFPB Database is counterintuitive, and does not conform to industry-standard, best-practices for relational database design. The current database design adds unnecessary complexity the processes required for each of the twelve to eighteen different products; and it makes it all but impossible to seamlessly add new products to the complaint process. (An alternative would be one primary, static database containing all the common elements across all products, and product-specific databases for each of the products in the CFPB Complaint Process.) The current design of the CFPB Complaint Process is predicated on the premise that all consumer complaint categorized into a single product, and then one or more Issues and/or sub-issues, can be used to identify the nature of the complaint; unfortunately, all products defined in the CFPB Complaint Process are different, and each product should have its own unique issues and sub-issues. (Example: This would allow the adjudication and dispute process for a large mortgage complaint to be differently from those of a small payday loan complaint.) The CFPB Complaint Process is designed on the premise that each complaint is distinct, and un-related to other complaints from the same consumer, (or even other consumers); and, this flawed, isolated view complaints, can cause the CFPB Complaint Process to miss patterns of possible-fraudulent practices that may have adversely affected hundreds, and in some instances, thousands of consumers, such as the 2016 Wells Fargo Bank account fraud, and the 2013 Chase RMBS Securitization Settlement. "THE COMPANY" ALWAYS WIN!

19. Suggestion for SAVING THE CFPB COMPLAINT PROCESS. CAN THE CFPB COMPLAINT PROCESS BE SAVED? YES; and from the consumer’s perspective, it would require virtually no change to their view of the CFPB Complaint Process; however from the perspective of both the CFPB Response Unit and “The Company”, process and functional changes would be required: a.) Additional fields such as those shown in the proposed CFPB Complaint Database Model should be added to the current CFPB Complaint Database; alternatively, this database design should be discarded, and new product-specific databases should be created for each product within the CFPB Complaint Process. b) New Issues, and/or Sub-Issues must be added to the CFPB complaint process; to more clearly define discriminatory complaints, based upon race, gender, age, religion, … c.) Removing unnecessary functionality from the Company Portal, including the removal of the complaint archival database, and limiting the portal to conduit for sending complaints to “The Company”, and receiving public responses and complaint arbitration documents from the “The Company”. (Copies of complaint documents sent/received via the Company Portal should be available to the consumer who filed the complaint via the FOIA.) d.) Closing consumer complaints would become the sole responsibility of the CFPB Complaint Response Unit, and would not occur until disputes and/or referrals to other agencies are completed. e.) The Complaint Dispute Process should be reactivated, and should become an integral, actionable component of the revised CFPB Complaint Process. f.) The list public responses provided by CFPB to “The Company”, be more clearly defined, and enhanced as necessary; and “The Company” would always be share its publicly responses, unless they would compromise the confidentially of the consumer. Finally, the final step before closing each CFPB consumer complaint, would be to request that the consumer provide a simple numerical rating of 1 to 5; for both the CFPB Consumer Response Unit, and “The Company”, and this survey would replace the current, meaningless consumer feedback process. "THE COMPANY" ALWAYS WIN! 19

20. How the Existing, CFPB Complaint Process “Really” Worked from December 2011 to April 2017: • Consumer complaints are placed on the Company Portal “within minutes” after being received. As this implies; CFPB does not review consumer complaints to ensure that they do not contain: • allegations of criminal fraud and/or other felonious criminal violations, • alleged violation of Civil Rights, and other federal laws, and; • violations of laws CFPB is empowered to enforced; such as, HMDA and ECOA. • These complaints should be reviewed by the CFPB Enforcement department, or to other federal or state enforcement agencies, before being sent to “The Company”. • CFPB sends the consumer complaint along with complaint narrative, and all supporting documentation to “The Company” via the Company Portal*. • “The Company” reviews the complaint and makes a unilateral, arbitration decision, and then sends a Closed Response to CFPB via the Company Portal. “The Company” closed responses include: • Closed without Explanation, • Closed with Explanation, • Closed with Monetary Relief, and; • Closed without Monetary Relief. • The Company” communicates its “final” arbitration decision to the consumers via mail. (Optionally, “The Company’s” can provide CFPB with permission to publish its Public Response in the CFPB Complaint Database, but it rarely does; thus depriving other American consumers, and other regulatory agencies, of this “vitally-important public information”.) • After receiving one of the above Closed Responses from “The Company CFPB, a.) Closes the consumer complaint, without first reviewing it to ensure that “The Company’s Closed response does not violate federal consumer finance, fair housing, or civil rights laws/acts, such as ECOA, FHA, and HMDA, and b.) updates CFPB Complaint Database. • Prior to April 2017: If the consumer disputed The Company’s response, “CFPB would promise to investigate” the complaint, and if necessary, re-open the complaint and re-file it with “The Company”, or refer it to another federal enforcement agency. • *The CFPB-provided “Company Portal”, which functions as a real-time, interactive web interface between CFPB and “The Company”, is an interactive, web interface includes an “Information Dashboard”, as well as a potpourri of CFPB apps, and archived complaint data; and a stream-line, “one-button” Complaint Response. Complaint Form. "THE COMPANY" ALWAYS WIN!

21. “SAVING THE CFPB COMPLAINT PROCESS.” • IF THE CONSUMER ACCEPTS THE COMPANY RESPONSES, THEN THE COMPLAINT IS CLOSED, AND NO FURTHER ACTION IS REQUIRED BY CFPB OR THE COMPANY. • HOWEVER, IF THE CONSUMER DOES NOT ACCEPT “THE COMPANY” RESPONSE, THEN: • CONSUMER MUST BE GIVEN THE OPTION TO “FORMALLY” DISPUTE THE COMPANY RESPONSE, INCLUDING THE OPPORTINITY TO CREATE A DISPUTE NARRATIVE THAT WOULD NOT BE IMMEDIATELY PLACED ON THE “COMPANY PORTAL”. • CFPB WOULD REVIEW THE DISPUTE NARRATIVE, AND THEN TAKE ONE OF THE FOLLOWING ACTIONS: • REJECT THE DISPUTE AND CLOSE THE COMPLAINT. • SEND A COPY OF THE COMPLAINT NARRATIVE TO THE COMPANY AND REQUEST A SECOND-LEVEL REVIEW OF THE CONSUMER’S DISPUTE NARRATIVE. IF THIS SECOND LEVEL REVIEWER’S RESPONSE IS THE SAME AS THE ORIGINAL RESPONSE, CFPB WOULD CLOSE THE COMPLAINT. • THE CURRENT CFPB OPTION OF REFERRING THE COMPLAINT TO OTHER FEDERAL , STATE OR LOCAL AGENCIES, WOULD BE UNCHANGED; BUT CFPB WOULD BE REQUIRED TO MONITOR REFERRED COMPLAINTS UNTIL THEY ARE SATISFACTORILY RESOLVED, AND INCLUDE THE FINAL COMPLAINT RESOLUTION IN THE CFPB COMPLAINT DATABASE. • THE EIGHT NEW FIELDS/ (SHOWN IN RED ON THE FOLLOWING PAGE) WOULD BE ADDED TO THE EXISTING CFPB COMPLAIN DATABASE; and FINALLY, CFPB WOULD ADD SEVERAL ANNUAL PERFORMANCE REPORTS TO ITS WEBSITE. SUGGESTED PERFORMANCE AREAS TO BE • MEASURED INCLUDE: DEMOGRAPHICS, PRODUCTS, ISSUES, COMPANIES, REFERRALS, • AND RESULTS OF CONSUMER SATISFACTION SURVEYS. "THE COMPANY" ALWAYS WIN!

22. "THE COMPANY" ALWAYS WIN!

23. How the CFPB Complaint Process “Should” Work: • 1. Complaint submitted (No change.) • You submit a complaint about an issue you have with a company about a consumer financial product or service. You will receive email updates and can log in to track the status of your complaint. • 2. Review and route (No changes other than reduced functionality in Company Portal.) • We'll forward your complaint and any documents you provide to the company* and work to get a response from them. If we find that another government agency would be better able to assist, we will forward your complaint to them and let you know. • 3. Company response (No change.) • The company reviews your complaint, communicates with you as needed, and reports back about the steps taken or that will be taken on the issue you identify in your complaint. • 4. Complaint published (Share all company responses sent to CFPB.)** • We publish information about your complaint—such as the subject and date of the complaint—on our public Consumer Complaint Database. With your consent we also publish your description of what happened, after taking steps to remove personal information. • 5. Consumer review (No change other than re-implementing dispute option for consumer, and making it actionable.) • We will let you know when "The Company" responds. You’ll be able to review The Company’s response, and will have 15 days to formally-dispute*** The Company's response. • We turn your complaint into action: • Complaints help with our work to supervise companies, enforce federal consumer financial laws, and write better rules and regulations. Learn more about how we use complaint data or explore the data on your own in the Consumer Complaint Database. • The current functionality of the Company Portal should be dramatically reduced, and the portal should become an electronic-conduit for sending complaints to “The Company”, and receiving “The Company’s” public-response to the complaint. All other functionality should be permanently removed from the Company Portal. (This does not prevent “The Company” from implementing and supporting functions currently supported by the Company Portal.) • ** The default should be to publish all non-personal information in complaints, including city, state, zip code, date of offence, and demographics; however, consumer should have the option to Opted out of publishing all demographic information. • *** CFPB should be required to implement an actionable-dispute process that would adjudicate complaints disputed by the consumer by simply ensuring that “The Company” responses did not violate any federal consumer protection statures within its jurisdiction; and, if questions arise, it should be empowered to refer disputed complaints to other federal or state agencies. "THE COMPANY" ALWAYS WIN!

24. ONE OF THE CENTER-PIECES OF THE DODD-FRANK ACT WAS THE CREATION A FEDERAL GOVERNMENT AGENCY THAT COULD ASSIST CONSUMERS DURING THE COMPLAINT RESOLUTION DUSPUTE PROCESS; HOWEVER, BASED ON THE TABLE SHOWN BELOW, IT IS UNLIKELY THAT ANY OF THE 82,260 COMPLAINTS SHOWN IN THIS TABLE WERE EVER ADJUDICATED BY CFPB. AFTER MORE THAN SEVEN YEARS IN EXISTANCE; the current CFPB Complaint Process: WHICH is LIKELY, “the greatest CONSUMER PROTECTION fraud ever perpetrated upon the American consumers”, is still IN OPERATION, AND IS currently viewed as an unparalleled success-STORY by MANY OTHER FEDERAL CONSUMER-COMPLAINT AGENCIES. THESE AGENCIES continue to, “BLINDLY” AND “UNCEROMONIOUSLY”: “Throw consumer complaints SUBMITTED TO THEIR Agencies, over the wall to INTO THE cfpb COMPLAINT process ABYSS”. The following TABLE includes a FIVE-YEAR summary of the, a.) CFPB COMPLAINT complaints, b.) disputed-complaints, and c.) disputed-complaints THAT WERE REFERRED FROM OTHER FEDERAL AND STATE AGENCIES. Click here to see details analysis complaints/disputes of Top-20 companies. "THE COMPANY" ALWAYS WIN!

25. CFPB WAS AUTHORIZED TO REFER THESE COMPLAINTS TO ITS OWN ENFORCEMENT UNIT, or OTHER GOVERNMENT AGENCIES FOR FURTHER INVESTIGATION; HOWEVER, AS SHOWN BELOW, CFPB SENT 6,585 Consumer Complaints Alleging, Identity theft, Fraud, or Embezzlement TO “THE Company” for ARBITRATION, and more than TWELVE HUNDRED of the CLOSED responses received from “The Company” were disputed by the consumer. REGRETTABLY, IT IS UNLIKELY THAT ANY OF TH 1,243 CONSUMERS EVER RECEIVE ANY FURTHER MEDIATION OF THEIR DISPUTED-COMPLAINTS. “COMPANY-CENTRIC DESIGN FLAWS”COMPANY-CENTRIC DESIGN FLAWS IN THE CFPB COMPLAINT PROCESS which ALLOWS “THE Company” to control the complaint arbitration process, AND to CLOSE ALL cfpb COMPLAINTS, WITHOUT RECOURSE. These design flaws potentially deprived TENS OF THOUSANDS OF CONSUMERS, of HUNDREDS of millions of dollars in monetary relief DURING THE PAST SEVEN YEARS! "THE COMPANY" ALWAYS WIN!

26. CFPB WEBSITE HOME PAGE: “SUBMITTING A COMPLAINT HELPS YOU AND OTHERS!” Although this webpage provides the perception that when consumers file complaints against “The Company” via the CFPB Complaint Process that “their complaints help others” However, the July 27,2018 snapshot CFPB Complaint Database shows that 93.4% of the 1,086,574 responses from “The Company” were not shared publicly; and thus, consumers had no awareness of how “The Company” responded to similar, or even identical, CFPB complaints as those being submitted. Click to see more about the lack of public-sharing of complaint responses by “The Company”. "THE COMPANY" ALWAYS WIN!

27. TOP-20 SUMMARY: FROM JANUARY TO DECEMBER 2016, THE CFPB COMPLAINT DATABASE SHOWS THAT 20 COMPANIES RECEIVED NEARLY ONE-THIRD (62.5%) OF THE 621,441 CFPB COMPLAINTS, AND THE REMAINING 4,148 COMPANIES, RECEIVED 121,986 CFPB COMPLAINTS. "THE COMPANY" ALWAYS WIN!

28. “TOP-20 COMPANIES HAVE “NO FEAR” OF THE CFPB COMPLAINT PROCESS.” TOP-20 SUMMARY: FROM JANUARY TO DECEMBER 2016, THE CFPB COMPLAINT DATABASE SHOWS THAT 20 COMPANIES RECEIVED NEARLY ONE-THIRD (62.5%) OF THE 621,441 CFPB COMPLAINTS, AND THE REMAINING 4,148 COMPANIES, RECEIVED 121,986 CFPB COMPLAINTS.(Continued) • THIS HUGE DISCREPANCY BETWEEN THE TOP-20 COMPANIES, AND THE REMAINING 4,148, IS FURTHER DISTORTED BY THE FACT THAT ALL TWENTY OF THESE COMPANIES, WITH THE EXCEPTION OF: BANK OF AMERICA, OCWEN, PNC BANK NA, AND HSBC NORTH AMERICA HOLDINGS, INC.; RECEIVED MORE CFPB COMPLAINTS IN 2016, THAN THEY DID IN 2015. CLEARLY, THERE WAS “NO FEAR” OF THE CFPB COMPLAINT PROCESS BY ANY OF THE TOP-20 COMPANIES, AND IN FACT, SOME OF THESE AND OTHER LARGE COMPANIES MAY HAVE “WELCOMED THE CFPB COMPLAINTS THEY RECEIVED”, BECAUSE: • THEY CONTROLLED THE CFPB COMPLAINT ARBITRATION PROCESS, AND COULD CLOSED COMPLAINTS WITHOUT FEAR OF RETRIBUTION BY EITHER CFPB OR ANY OTHER GOVERNMENT CONSUMER COMPLAINT/CONSUMER PROTECTION AGENCY, AND; ONCE CLOSED, CFPB COMPLAINTS ARE VIRTUALLY IMPOSSIBLE TO BE RE-OPENED, OR TO BE RE-FILED, BECAUSE THE COMPANY PORTAL PROVIDES “THE COMPANY” WITH A COMPLAINT ARCHIVE WHICH CONTAINS ALL PREVIOUSLY CLOSED COMPLAINTS, AS WELL AS ANY PREVIOUSLY REJECTED DUPLICATE COMPLAINTS. "THE COMPANY" ALWAYS WIN!

29. “TOP-20 COMPANIES HAVE NO FEAR OF THE CFPB COMPLAINT PROCESS.” TOP-20 SUMMARY: FROM JANUARY TO DECEMBER 2016, THE CFPB COMPLAINT DATABASE SHOWS THAT 20 COMPANIES RECEIVED NEARLY ONE-THIRD (62.5%) OF THE 621,441 CFPB COMPLAINTS, AND THE REMAINING 4,148 COMPANIES, RECEIVED 121,986 CFPB COMPLAINTS. (Continued) • AS OPPOSED TO OTHER GOVERNMENT CONSUMER COMPLAINT PROCESSES, THE CFPB COMPLAINT PROCESS DOES NOT HAVE A DISPUTE OR ESCALATION OPTION; AND THUS, WHEN A CFPB COMPLAINT IS CLOSED BY “THE COMPANY”, IT IS EFFECTIVELY “DEAD”. TO EMPHASIZE THIS POINT: CONSUMERS WHO ATTEMPT TO SEEK RELIEF VIA “THE COURTS”, FACE A FORMIDABLE, UP-HILL BATTLE, BECAUSE “THE COMPANY” CAN USE THE CFPB’S “KISS OF DEATH” APPROVAL OF ITS CLOSING RESPONSE AS PART OF ITS DEFENSE. • GIVEN THE ABOVE ARGUMENTS, IT IS HIGHLY-PROBABLE THAT CONSUMERS WOULD RECEIVE THE SAME, OR BETTER RESULTS, IF THEY HAD FILED THEIR COMPLAINTS DIRECTLY WITH THE COMPANY, AND AVOIDED CONTAMINATING THEIR COMPLAINT WITH THE DREADED CFPB “KISS OF DEATH” APPROVAL OF THE COMPANY’S RESPONSE. • CLICK FOLLOWING LINKS TO VIEW ANALYSIS OF TOP-20 CLOSED RESPONSES: "THE COMPANY" ALWAYS WIN!

30. COMPANY-CENTRIC Consumer Financial protection bureau (CFPB) COMPLAINT PROCESS SUMMARY THE CFPB WEBSITE AT: HTTPS://WWW.CONSUMERFINANCE.GOV/, CLAIMS THAT CURRENT CFPB COMPLAINT PROCESS HAS BEEN AN UNQUALIFIED SUCCESS, SINCE IT WAS IMPLEMENTED ON DECEMBER 1, 2011; HOWEVER, THE COMPANY-CENTRIC DESIGN OF THIS PROCESS, IN COMBINATION, WITH THE CFPB COMPLAINT DATABASE, REVEALS A MUCH DIFFERENT, AND DISTURBING PERSPECTIVE OF THIS FLAWED COMPLAINT-RESOLUTION PROCESS. Can the current CFPB Complaint Process be saved? "THE COMPANY" ALWAYS WIN!

31. does THE “C” IN CFPB ABRIVATION FOR Consumer-financial-protection-bureau, or COMPANY-FINANCIAL-PROTECTION-BUREAU? THE BEST-CASE SCENARIO FOR CFPB COMPLAINT PROCESS: DURING THE PAST SEVEN YEARS, THE CFPB COMPLAINT PROCESS PROVIDED CONSUMERS WITH A US GOVERNMENT-MANAGED, CONSUMER COMPLAINT REPOSITORY, AND A PASSIVE, SEAMLESS CONDUIT FOR SENDING FINANCIAL-RELATED COMPLAINTS TO “THE COMPANY” FOR ARBITRATION. THE WORST-CASE SCENARIO FOR CFPB COMPLAINT PROCESS: DURING THE PAST SEVEN YEARS, CFPB DENIED KEY ELEMENTS OF “DUE PROCESS” TO THE MORE THAN A MILLION CONSUMERS WHO, IN GOOD FAITH, FILED CONSUMER COMPLAINTS VIA THE FLAWED CFPB COMPLAINT PROCESS. ALL OF THESE CONSUMERS WERE LED TO BELIEVE THAT THEY HAD SUBMITTED ACTIONABLE COMPLAINT TO A US GOVERNMENT AGENCY, THAT WOULD ASSIST THEM IN OBTAINING FAIR, EQUITABLE RESOLUTIONS TO THEIR FINANCIAL COMPLAINTS. AT NO TIME WERE THESE CONSUMERS INFORMED THAT THEIR COMPLAINTS WOULD NOT BE REVIEWED BY CFPB, AND THAT THEIR COMPLAINTS WOULD BE ARBITRATED, SOLELY BY “THE COMPANY”; WITHOUT ANY ACTIVE PARTICIPATION BY CFPB. HAD THESE CONSUMERS BEEN INFORMED THAT “THE COMPANY” WOULD ACT AS “JUDGE, JURY, AND APPELLATE” FOR THEIR COMPLAINTS; AND THAT CFPB WOULD NEVER APPROVE AND RATIFY ALL ARBITRATION RESPONSES FROM “THE COMPANY”, AND WOULD THEN “LIE” TO CONSUMERS ABOUT THE EXISTENCE OF A COMPLAINT DISPUTE PROCESS, THE VAST MAJORITY WOULD HAVE FILED THEIR COMPLAINTS DIRECTLY WITH “THE COMPANY” RATHER THAN USE THE FICTITIOUS CFPB COMPLAINT PROCESS. BASED UPON HOW THE CURRENT CFPB COMPLAINT PROCESS ACTUALLY WORKS, THE “C” IN CFPB, IS REALLY FOR “COMPANY”, RATHER THAN “CONSUMER”; AND THEREFOTE, IT IS UNDERSTANDABLE WHY WHEN CONSUMERS FILE FINANCIAL-RELATED COMPLAINTS WITH THE COMPANY-FINANCIAL-PROTECTION-BUREAU, “THE COMPANY” ALWAYS WINS! "THE COMPANY" ALWAYS WIN!

32. “THE GREAT AND POWERFUL WIZARD OF OZ” CARICATURE CFPB COMPLAINT PROCESS ”COMPANY-CENTRIC” DESIGN: IS THE PERSONIFICATION OF A WIZARD OF OZ TYPE ADUJUDICATION PROCESS; AND THE CLANDESTINE COMPANY PORTAL PROVIDES “THE COMPANY” WITH UNRESTRICTED ACCESS CURRENT AND ARCHIVED COMPLAINTS STORED IN THE CFPB DATABASE. “THE GREAT AND POWERFUL COMPANY ARBITRATOR” “THE COMPANY” CLANDESTINE COMPANY PORTAL CFPB Complaint Data, Archived Complaints, and CFPB Complaint Database. WHEN THE GREAT, AND POWERFUL COMPANY ARBITRATOR RENDERS ITS FINAL DECISIONS, THEY ARE ALWAYS THE SAME: “THE COMPANY” WINS 80% TO 90% OF THE TIME! BETWEEN 2011 AND 2017, MORE THAN ONE MILLION CFPB COMPLAINTS WERE SENT TO “THE COMPANY” VIA COMPANY PORTAL “YELLOW-BRICK ROAD”. "THE COMPANY" ALWAYS WIN!

33. UNSUBSTANTIATATED: “STANDING UP FOR YOU” CLAIMS BY CFPB! THE FOLLOWING GRAPHIC IS FOUND ON THE HOME PAGE OF THE CFPB WEBSITE; AND CLAIMS THAT CFPB HAS PROVIDED12.4 BILLION DOLLARS IN RELIEF TO 31MILLION CONSUMERS, AND THAT CFPB HAS HANDLED MORE THAN 1.5 MILLION COMPLAINTS; AND THAT 97% OF ALL CONSUMER COMPLAINTS WERE RESPONDED TO IN A “TIMELY MANNER”. HOWEVER, IT FAILS TO MENTION THAT MORE THAN EIGHTY PERCENT OF THESE COMPLAINTS, WHICH WERE RESPONDED TO IN A “TIMELY MANNER”, RECEIVED “CLOSED” OR “CLOSED WITH EXPLANATION” RESPONSES FROM “THE COMPANY”, AND LESS THAN SEVEN PERCENT WERE “CLOSED WITH MONETARY RELIEF”; AND FURTHER, THAT THERE WAS NO REVIEW, DISPUTE, APPEAL, OR ESCALATION OF ANY THE 743,427 CFPB COMPLAINTS ARBITRATED BY “THE COMPANY” PRIOR TO MARCH 2017! "THE COMPANY" ALWAYS WIN!

34. CFPB WEBSITE HOME PAGE: “STANDING UP FOR YOU CLAIMS!” THE STATISTICS SHOWN IN THE “STANDING UP FOR YOU” GRAPHIC ON THE PREVIOUS PAGE, CLAIMS THAT CFPB HAS PROVIDED 12.4 BILLION DOLLARS IN RELIEF TO 31 MILLION CONSUMERS, AND THAT THE CFPB COMPLAINT PROCESS HAS HANDLED MORE THAN 1.1 MILLION COMPLAINTS; WITH CONSUMERS RECEIVED TIMELY RESPONSES TO THESE COMPLAINTS, 97% OF THE TIME. • THE CFPB WEBSITE, FAILS TO MENTION THAT THE 97.% TIMELY RESPONSE WAS ACHIEVED BECAUSE OF THE EXISTENCE OF A TWO-WAY, REAL-TIME PORTAL BETWEEN CFPB AND “THE COMPANY”, AND SOME OR ALL OF THE OTHER INDICATORS SHOWN IN THE AFOREMENTIONED GRAPHIC, WERE ACHIEVED IN CFPB AREAS OTHER THAN THE CFPB COMPLAINT DEPARTMENT. THE MARCH 2017 SNAP-SHOT OF CFPB COMPLAINT DATABASE, CLEARLY ILLUSTRATE THAT THESE “STANDING UP FOR YOU” STATISTICS COULD NEVER BE ACHIEVED CFPB COMPLAINT DEPARTMENT, BECAUSE, CFPB ONLY PLAYS A MINOR, “ADMINISTRATIVE” ROLE AS A COMMUNICATION CONDUIT, IN THE COMPLAINT RESOLUTION PROCESS; AND THUS “THE COMPANY” IS THE REAL WINNER, BECAUSE MORE THAN 80% OF ALL COMPLAINTS ARE CLOSED WITHOUT RELIEF, AND ONLY 6.7% COMPLAINTS ARE CLOSED WITH MONETARY RELIEF TO CONSUMERS. THE ACTUAL NUMBER OF CFPB COMPLAINTS PROCESSED BY CFPB IS UNKNOWN, BECAUSE THE COMPANY CAN REQUEST THAT CERTAIN CFPB COMPLAINTS NOT BE PUBLISHED IN THE DATABASE; HOWEVER, DURING THE PREVIOUS SIXTEEN MONTHS, THE CFPB DATABASE CONTAINED*: • Date# of Complaints • September 2016 636,057 • March 2017 743,427 • December 2017 918,573 • July 2018 1,086,574 • *“The Company” can request that certain CFPB complaints not be published in the database. "THE COMPANY" ALWAYS WIN!

35. ACTUAL CFPB “STANDING UP FOR YOU” RESULTS! THE FOLLOWING TABLES SHOWS THE ACTUAL COMPANY RESPONSES (TOTALS AND PERCENTAGES) TO 743,427 CFPB COMPLAINTS FILED BETWEEN DECEMBER 2011 AND APRIL 24, 2017. THESE TABLES SHOW THAT “THE COMPANY” WINS EIGHTY PERCENT OF ALL CFPB COMPLAINTS, AND LOSE TWENTY PERCENT OF COMPLAINTS FILED VIA CFPB. IT IS IMPORTANT THAT “THE COMPANY” RESPONSES THAT INCLUDED MONETARY RELIEF WAS LESS THAN 7%! "THE COMPANY" ALWAYS WIN!

36. CFPB WEBSITE CLAIMS: “SUBMITTING A COMPLAINT HELP OTHERS” BUT “THE COMPANY” RARELY SHARES IT PUBLIC RESPONSES. As the table below shows, only 5.9% of responses from “the company” are shared publicly; and some large national banks, and financial services companies do not share any of their responses publicly. The Company’s unwillingness to share public responses is likely because it “ONLY DISPUTES THE FACTS PRESENTED BY THE CONSUMER 0.35% OF THE TIME”. "THE COMPANY" ALWAYS WIN!

37. FOR MORE DETAILS, PLEASE VISIT HTTP://WWW.CFPBCOMPLAINTMONITOR.ORG. (ALSO, CLICK HERE TO VIEW A PRINTABLE VERSION OF THIS PRESENTATION.) Please send comments to info@cfpbcomplaintmonitor.org "THE COMPANY" ALWAYS WIN!

38. “COMPLAINT DISPUTES VERSUS CONSUMER FEEDBACK.”SHAMEFULLY, IT NOW APPEARS THAT THERE WAS NEVER AN ACTIONABLE-DISPUTE OPTION WITHIN THE cfpb complaint process; HOWEVER, BETWEEN 2011 AND 2017 consumers were ALLOWED TO DISPUTE RESPONSES RECEIVED FROM “THE Company”, if they did not agree with the arbitration decision, AND DURING THIS SEVEN-YEAR PERIOD, THEY FOLLOWED INSTRUCTIONS SHOWN ON THE cfpb website, and formally-Disputed a total of 145,150 RESPONSES” RECEIVED FROM “THE COMPANY”. EACH OF THE FOLLOWING COMPANIES, HAD MORE THAN FIVE THOUSANDS DISPUTED COMPLAINTS BETWEEN DECEMBER 2011 THROUGH APRIL 2017; AND THESE DISPUTES WERE APPARENTLY “DISCARDED” BY CFPB, WITHOUT ANY FURTHER ACTION BEING TAKEN: "THE COMPANY" ALWAYS WIN!

39. “COMPLAINT DISPUTES VERSUS CONSUMER FEEDBACK.”SHAMEFULLY, IT NOW APPEARS THAT THERE WAS NEVER AN ACTIONABLE-DISPUTE OPTION WITHIN THE cfpb complaint process; HOWEVER, BETWEEN 2011 AND 2017 consumers were ALLOWED TO DISPUTE RESPONSES RECEIVED FROM “THE Company”, if they did not agree with the arbitration decision, AND DURING THIS SEVEN-YEAR PERIOD, THEY FOLLOWED INSTRUCTIONS SHOWN ON THE cfpb website, and formally-Disputed a total of 145,150 RESPONSES” RECEIVED FROM “THE COMPANY”. Continued) • IN MAY 2017, after CFPB ACKNOWLEDGED THAT THERE WAS NEVER AN ACTIONABLE-DISPUTE OPTION AVAILABLE IN THE CFPB COMPLAINT PROCESS, it THEN UNCEREMONIOUSLY, RE-CLASSIFIED THE 145,150 DISPUTES FILED BY CUSTOMERS, AS “CONSUMER FEEDBACKS”. UNFORTUNATELY, FROM THE CONSUMER’S PROSPECTIVE, any attempts to resubmit these complaints to cfpB; or any other FEDERAL OR STATE CONSUMER COMPLAINT agency, WERE summarily-rejected, because BOTH the cfpb complaint database, AND The “COMPANY PORTAL”, would show that these complaints had already: • BEEN submitted to “the Company” by CFPB, AND THAT “The company” arbitrated THEM, and then closed these complaints, and ALSO “ERRONIOUSLY” SHOW THAT; • CONSUMER’S DISPUTE of the company’s arbitration decisions, HAD BEEN REVIEWED rejected by both cfpb, and “the company”. • THE NEGATIVE IMPACT OF THIS DECEPTION ON CONSUMERS IS INCALCULABLE, BECAUSE THEY FALSELY BELIEVED THAT THEIR DISPUTES HAD BEEN meticulously REVIEWED BY a federal consumer complaint agency, and that the review of this agency WAS equivalent to a “government” adjudication of “The Company” Response. "THE COMPANY" ALWAYS WIN!

40. “THE COMPANY” Had NO FEAR OF THE CFPB COMPLAINT PROCESS! FINANCIAL SERVICES COMPANIES, AND NATIONAL ASSOCIATION BANKS, maintained a quasi-partnership relationship with cfpb, and THE ALL-SEEING “COMPANY PORTAL” enables “THE COMPANY’S”EXPERIENCED CONSUMER COMPLAINT resolution staff TO HAVE UNRESTRICTED ACCESS TO THE BOTH CURRENT, AND ARCHIVED COMPLAINTS RESIDING IN THE CFPB complaint DATABASE. • BETWEEN 2011 AND 2017, THERE HAS BEEN YEAR-OVER-YEAR INCREASES IN THE NUMBER OF CFPB COMPLAINTS SUBMITTED TO COMPANIES: • DURING THIS PERIOD, THE NUMBER OF COMPANIES TO WHICH CFPB SUBMITTED CONSUMER COMPLAINTS, MORE THAN DOUBLE: FROM 1,429 TO 3,299. • THE ANNUAL CONSUMER COMPLAINTS SENT TO THESE COMPANIES MORE THAN DOUBLED: FROM 108,218 TO 232,361. • THE TOP-20 COMPANIES TO WHICH COMPLAINTS SUBMITTED INCREASED FROM 76,376 IN 2013, TO 143,377 IN 2017. • THE ANNUAL INCREASE OF CFPB COMPLAINTS SENT TO COMPANIES CLEARLY ILLUSTRATES THAT THESE COMPANIES HAD “NO FEAR” OF THE ARBITRATION, AND ENFORCEMENT PROVISIONS IN THE CFPB COMPLAINT PROCESS; AND, BECAUSE OF A FLAW IN THE COMPANY-CENTRIC DESIGN OF THIS COMPLAINT PROCESS, SOME COMPANIES APPEAR TO HAVE ACTUALLY WELCOMED THIS INCREASED NUMBER OF COMPLAINTS; BECAUSE ONCE “THE COMPANY” CLOSE A COMPLAINT, AND OBTAINS CFPB’S “RUBBER-STAMP” APPROVAL OF ITS CLOSED RESPONSE, NO FURTHER ACTION WAS TAKEN, AND FOR ALL “INTENT AND PURPOSE”, THIS COMPLAINT WAS DEAD. "THE COMPANY" ALWAYS WIN!

41. WHAT IS THE MISSION OF CFPB? The cfpb website at http://www.cfpb.gov/process states that the “Central Mission of CFPB...is to make markets for consumer financial products and services work for Americans—whether they are applying for a mortgage, choosing among credit cards, or using any number of other consumer financial products".In 2016 alone most of the hundreds of thousands of consumer complaints about their financial services—including banks and credit card issuers—were received and compiled by CFPB and are publicly available on a federal government database, known as the CFPB Complaint Database. • CFPB WORK INCLUDE: • Rooting out unfair, deceptive, or abusive acts or practices by writing rules, supervising companies, and enforcing the law. • Enforcing laws that outlaw discrimination in consumer finance.* • Taking consumer complaints*. • Enhancing financial education. • Researching the consumer experience of using financial products. • Monitoring financial markets for new risks to consumers. * Primary accountabilities of the CFPB Complaint Process. "THE COMPANY" ALWAYS WIN!

42. THE CURRENT “COMPANY-CENTRIC” CFPB COMPLAINT DATABASE DESIGN. Click here to see descriptions of all notes. https://files.consumerfinance.gov/f/documents/201704_cfpb_Consumer_Complaint_Form_Product_and_Issue_Options.pdf "THE COMPANY" ALWAYS WIN!

43. “IMPORTANCE OF THE COMPANY’S PUBLIC RESPONSE” THE COMPANY’S PUBLIC RESPONSES TO CFPB COMPLAINTS ARE OF ENORMOUS IMPORTANCE, BECAUSE THEY PROVIDE OTHER CONSUMERS, AND REGULATORY AGENCIES, WITH HISTORICAL INFORMATION, REGARDING HOW SIMILAR COMPLAINTS WERE ARBITRATED BY “THE COMPANY”. Red-shaded entries show that only 5.94% of all Company complaint responses were shared publicly. "THE COMPANY" ALWAYS WIN!

44. “CONSUMER FEEDBACK?” THE CFPB COMPLAINT DATABASE SHOWS THAT FROM DECEMBER 1, 2011 THROUGH MARCH 24, 2017, CONSUMERS DISPUTED 145,150 (19.5%) OF 743,427 RESPONSES FROM “THE COMPANY”, BUT IN REALITY, THERE WAS NEVER A DISPUTE OPTION WITHIN THE CFPB COMPLAINT PROCESS; AND CFPB NOW CLASSIFIES THESE “DISPUTES” AS “CONSUMER FEEDBACK”. Note: It is unclear what role, if any, Consumer Narratives play in the Company’s Complaint Arbitration Process, but Consumer Narratives were only received in CFPB Complaints submitted via the web, and not available for CFPB Complaints received via Email, Fax, Phone, Postal mail, or Referrals. Click here to see top-25 reasons why the current CFPB Complaint Process does not work. "THE COMPANY" ALWAYS WIN!

45. CFPB COMPLAINT PRODUCTS AND SUB-PRODUCTS. THE CFPB COMPLAINT PROCESS INCLUDES TWELVE (12*) PRODUCTS, AND FORTY-EIGHT (48) SUB-PRODUCT, WITH WHICH TO CATEGORIZE THE FINANCIAL PRODUCTS AND SERVICES FROM WHICH CFPB COMPLAINTS COULD BE CREATED. *The number of products was recently expanded from 12 to eighteen. Click following link to see a complete list of Products and Issues: https://files.consumerfinance.gov/f/documents/201704_cfpb_Consumer_Complaint_Form_Product_and_Issue_Options.pdf "THE COMPANY" ALWAYS WIN!

46. CFPB COMPLAINT DATABASE CONTAINED 743,427 CONSUMER COMPLAINTS; AND ALL COMPLAINTS WITH THE EXCEPTION OF 4,037 IN-PROGRESS RESPONSES, AND 4,010 UNTIMELY RESPONSES, WERE ADJUDICATED, AND CLOSED BY “THE COMPANY”. Click here to see a list of 48 sub-products. *The number of products was recently expanded from 12 to eighteen. "THE COMPANY" ALWAYS WIN!

47. ONE OF THE MOST IMPORTANT FEATURES OF THE CFPB COMPLAINT PROCESS IS THE PUBLIC-SHARING OF COMPLAINT RESOLUTION DATA WITH BOTH CONSUMERS, AND OTHER REGULATORY AGENCIES. THIS FEATURE ENABLES CONSUMERS TO SEE HOW “THE COMPANY” RESPONDED TO PREVIOUS CONSUMER COMPLAINTS, AND ALSO ALLOWS REGULATORY AUTHORITIES TO ENSURE THAT “THE COMPANY” IS CONFORMING TO CONSUMER PROTECTION LAWS AND REGULATIONS. "THE COMPANY" ALWAYS WIN!

48. “THE COMPANY” PUBLICLY DISPUTES THE FACTS PRESENTED BY CONSUMERS 0.4% OF THE TIME!” “THE COMPANY”ONLY DISPUTES THE FACTS IN CFPB COMPLAINT 0.4% OF THE TIME; YET IT CHOOSES NOT TO PUBLICLY-SHARE ITS RESPONSES TO CONSUMERS: 87.0%! THIS STATISTIC CLEARLY-DEMONSTRATES, THAT MANY, IF NOT MOST, OF “THE COMPANY” RESPONSES ARE SUBJECTIVE, RATHER THAN OBJECTIVE; AND NOT BASED UPON THE ACTUAL COMPLAINT FILED BY THE CONSUMER. "THE COMPANY" ALWAYS WIN!

49. CFPB CONSUMER COMPLAINT - FOUR CLOSED RESPONSES THE FOUR PRIMARY CLOSED RESPONSES WITHIN THE CFPB COMPLAINT PROCESS ARE: CLOSED. CLOSED WITH EXPLANATION. CLOSED WITH MONETARY RELIEF. CLOSE WITHOUT MONETARY RELIEF. AS OF APRIL 30, 2017, THE CFPB COMPLAINT DATABASE CONTAINED 743,427 CONSUMER COMPLAINTS, AND 712,219 OF THESE COMPLAINTS WERE CLOSED BY “THE COMPANY”, WITH A WINNING PERCENTAGE OF 80.1%; AND BECAUSE THERE ARE NO DISPUTE OR APPEAL OPTIONS WITHIN THE CFPB COMPLAINT PROCESS, CONSUMERS ARE “FORCED” TO ACCEPT “THE COMPANY” RESPONSES. "THE COMPANY" ALWAYS WIN!

50. WINNING PERCENTAGE OF “CLOSED WITH EXPLANATION” RESPONSE • THE “CLOSE WITH EXPLANATION “ RESPONSE SENT TO CONSUMERS IS ONE OF THE FOUR CLOSED RESPONSES ALSO SENT TO CFPB BY: • CLOSED RESPONSEDESCRIPTION OF CLOSED RESPONSE • CLOSED: CLOSED WITH NO EXPLANATION AND NO RELIEF. • CLOSED WITH EXPLANATION: CLOSED WITH ONE OF SEVEN EXPLANATIONS. • CLOSED WITH MONETARY RELIEF: CLOSED WITH MONETARY RELIEF TO THE CONSUMER. • CLOSED WITH NON-MONETARY RELIEF: CLOSED WITHOUT MONETARY RELIEF TO THE CONSUMER. • THE FOLLOWING TABLE SHOWS THE ANNUAL TOTALS FOR EACH OF THESE CLOSED RESPONSES, PLUS SEVEN-YEAR TOTALS, AND PERCENTAGES FOR ALL FOUR CLOSED RESPONSES. "THE COMPANY" ALWAYS WIN!