RE: FOIA Request #CFPB-2016-095-F
December 30, 2015
Mr. Robert Delaware
MuckRock News
DEPT MR 23044
P.O. Box 55819
Boston, Massachusetts 02205-5819
Dear Mr. Delaware:
This letter is in final response to your Freedom of Information Act (FOIA) request dated
December 21, 2015. Your request sought a copy of all complaints received by the CFPB
regarding Virtual Currency Products and Services.
A search of our Office of Consumer Response for documents responsive to your request
produced a total of 5177 entries in a Microsoft Excel Spreadsheet. The attached spreadsheet is
granted in full, no deletions or exemptions have been claimed on these records. However, other
fields, data and attachments related to consumer complaints have been withheld in full pursuant
to the Privacy Act (5 U.S. C. § 552a) and Exemption 4, 5, 6, 7(D), 7(E), and 8 of the FOIA (5
U.S.C. § 552).
Additionally, I have determined that response letters that have been issued to individual
complainants as well as response letters from financial institutions would also be responsive to
your request. I have determined that these letters should be withheld in their entirety under FOIA
Exemptions 4 and 6.
We note that, to the extent that Exemption 6 or any other FOIA exemption applies to certain data
fields, the Privacy Act prohibits the Bureau from disclosing such data without the consent of the
consumers or pursuant to another Privacy Act exemption. The withheld records are part of CFPB
system of records .005 – Consumer Response Database. This information is confidential
information as defined in Bureau regulations at 12 C.F.R. § 1070.2(f).
FOIA Exemption 4
This exemption protects trade secrets and commercial or financial information obtained from a
person that is privileged or confidential. The courts have held that this subsection protects (a)
confidential commercial information, the disclosure of which is likely to cause substantial harm
to the competitive position of the person who submitted the information and (b) information that
was voluntarily submitted to the government if it is the kind of information that the provider
would not customarily make available to the public. I have reviewed the responsive data fields

 and relevant case law, and determined that information in certain fields is exempt from
disclosure under FOIA Exemption (b)(4).
FOIA Exemption 5
This exemption protects from disclosure, those inter- or intra-agency documents that are
normally privileged in the civil discovery context. The three most frequently invoked privileges
are the deliberative process privilege, the attorney work-product privilege, and the attorney-client
privilege. After carefully reviewing the responsive documents, I have determined that the
information in the data fields listed above qualifies for protection under the Deliberative
Process Privilege. This privilege protects the integrity of an agency’s decision-making
processes. This privilege permits an agency to withhold from disclosure intra- and inter-agency
communications that are pre-decisional and deliberative in nature, including but not limited to
suggestions or recommendations for future agency decisions or actions. Such communications
are subject to the privilege to the extent that their release would reasonably be expected to inhibit
the free and frank exchange of information among agency personnel, reveal prematurely the
agency’s plans for future decisions or actions, or confuse the public as to the true nature of or
basis for the agency’s decisions and actions.
In this instance, the deliberative process privilege applies to the data in certain fields because
such data consist of preliminary assessments made by Bureau employees as to how to classify,
route, process and otherwise address the complaints that the Bureau has received. In certain
instances, the data do not reflect accurately the final disposition of these complaints once they
have been reviewed or investigated by others in the Bureau such that public disclosure of the
data would confuse the public as to the nature of the Bureau’s actions in response to the
complaints. Disclosure of these data may also reveal prematurely how the Bureau plans to handle
complaints that are still pending. Finally, the Bureau is concerned that public disclosure of its
employees’ preliminary assessments of complaints would inhibit them from making such
assessments in the future, thereby compromising the Bureau’s efforts to properly process these
complaints.
FOIA Exemption 6 and the Privacy Act
FOIA Exemption 6 exempts from public disclosure information the release of which would
result in a clearly unwarranted invasion of personal privacy. For Exemption 6 to apply to
information, an agency must determine that an individual has a substantial privacy interest in the
information that outweighs any corresponding public interest in the disclosure of the
information.
Consumers have a substantial interest in protecting the confidentiality of information that they
submit to the CFPB as part of their complaints where such information could reasonably be
expected to identify such consumers, either directly or indirectly, and where consumers have
not consented to release of their information. Reputational, financial, and other harms may
ensue for consumers whose identities as CFPB complainants are revealed to the public. Due
to the risk of consumer harms associated with disclosure and lack of consumers’ consent to

 release their information, we conclude that consumers’ privacy interests outweigh any public
interest in the disclosure of identifying information.
The information that the CFPB withholds from disclosure includes the names, contact
information, and demographics of complainants insofar as such data either identifies
complainants directly or could be combined with other information to identify complainants
indirectly. Additionally, we withhold correspondence received by consumers under FOIA
Exemption (b)(6).
For similar reasons, we withhold complaint narratives that do not meet the criteria outlined in our
final Consumer Complaint Narrative Policy. Complaint narratives often include complainants’
names, the names of their family members, the numbers and details of their credit cards and
financial accounts, and other highly-sensitive information. As such, the Bureau seeks consumer
consent to release narratives that have been subjected to a process for removing personal
information. Consumers consent to the release of their narratives with the express understanding
that, while their narratives would be processed to remove personal information, there remains a
risk of “re-identification” or a release of personal information. To access complaint narratives
that meet the policy’s requirements, please visit the Consumer Complaint Portal at
www.consumerfinance.gov/complaint database.
Also on the basis of Exemption 6, we withhold fields that identify CFPB employees who are or
who have been assigned to process or investigate CFPB complaints. These employees have an
interest in maintaining their anonymity to protect them from harassment. Again, we believe that
this interest outweighs any corresponding public interest in the disclosure of employees’
identities.
FOIA Exemption 7
Exemption 7(D) protects records or information compiled for law enforcement purposes, the
release of which could reasonably be expected to disclose the identities of confidential sources.
After carefully reviewing the responsive fields, I determined that the information in the
whistleblower field could reasonably be expected to contain whistleblower information related to
consumer complaints.
Exemption 7(E) protects records compiled for law enforcement purposes, the release of which
would disclose techniques and/or procedures for law enforcement investigations or prosecutions,
or would disclose guidelines for law enforcement investigations or prosecutions if such
disclosure could reasonably be expected to risk circumvention of the law. I have determined that
the disclosure of the investigations table, and other records generated in the course of
investigation of consumer complaints, would reveal non-public internal investigative techniques,
procedures, guidelines, patterns or practices and could adversely affect future investigations and
operations by exposing the details and type of information the Bureau uses in the course of an
investigation. The disclosure of these patterns and practices could permit people seeking to
violate consumer protection laws and regulations to circumvent the law by taking proactive steps
to alter their behavior to further conceal criminal or other illegal activity, and otherwise counter
operational and investigative actions taken by the Bureau.

 FOIA Exemption 8
This exemption protects matters that are contained in or related to examination, operating, or
condition reports prepared by, on behalf of, or for the use of an agency responsible for the
regulation or supervision of financial institutions. Additionally, it ensures the security of
financial institutions, which could be undermined by disclosure of information containing frank
evaluations of such institutions, and a secondary purpose of safeguarding the relationship
between the banks and their supervising agencies. I have reviewed the responsive data fields and
relevant case law, and I determined that certain fields are exempt from disclosure under
subsection (b)(8) of the FOIA.
You may appeal any of the responses or decisions set forth above. If you choose to file an
appeal, you must do so within 45 calendar days from the date of this letter. Your appeal must be
in writing, signed by you or your representative, and should contain the rationale for the appeal.
You may send your appeal via the mail (address below), email (FOIA@cfpb.gov) or fax (1-855FAX-FOIA (329-3642)).
Your appeal should be addressed to:
Consumer Financial Protection Bureau
Attention: Chief FOIA Officer
Freedom of Information Appeal
1700 G Street, NW
Washington, D.C. 20552
Provisions of the FOIA allow us to recover part of the cost of complying with your request.
However, in this instance, we have waived all fees related to the processing of your request.
For questions concerning our response, please feel free to contact CFPB’s FOIA Service Center
by email at FOIA@cfpb.gov or by telephone at 1-855-444-FOIA (3642).
Sincerely,

Mark Vugrinovich
FOIA Manager
Operations Division