During my first two years at the Consumer Financial Protection Bureau (CFPB), I served as the Design Lead for the Office of Consumer Response, which is responsible for accepting complaints from the public about financial products and services. Since the office began accepting complaints in July 2011, it has handled over 700,000 complaints through web, phone, and paper channels. Our design team included two graphic designers, a front-end developer, and myself, and we also worked closely with a Technology Portfolio Manager from the Bureau’s Program Management Office.
Our first challenge was winning hearts and minds: the stakeholders managing the Bureau’s complaint service had been working with a large technology vendor for the previous two years to manage their Customer Relationship Management (CRM) system and its corresponding web forms, and felt that our in-house designers could be helpful for adjusting fonts and colors near the end of a project, but not much else. In order to improve the experience of submitting a complaint, we needed to demonstrate how user research, prototyping, and user-centered design could fit into their development processes.
When a consumer submits a complaint to the CFPB, the Bureau works to forward it directly to the appropriate company for a response, and the company is then required to respond within 15 days. This process required the Bureau to establish relationships with thousands of financial institutions, so the early team launched the system by first accepting complaints about credit cards, then opening up the system for mortgages, bank accounts, auto loans, student loans, credit reporting, and money transfers over the course of two years. For each new product type, they created a new web form (this is despite the fact that the questions on each form are almost identical – we’ll get to that later.)
When our design team was assembled, our stakeholders were working on a new form for complaints about debt collection, and new forms for payday loans and prepaid cards were scheduled for later in the year. The style and structure for the existing forms didn’t match with the CFPB’s brand standards and didn’t comply with general web best practices, so we quickly got to work prototyping new designs for the complaint forms.
We used these early prototypes to talk about the possibility of redesigning the complaint forms for the upcoming releases. Most conversations were conducted 1-on-1 with top stakeholders or in small groups with different teams within the organization, with a goal of receiving feedback and establishing consensus over time (this was much more effective than holding a “big reveal” presentation that might take people by surprise). After a few months of iterations and feedback, our new design was approved with wide support, and it went live with the launch of the debt collection complaint forms in July 2013, and was also used for the launch of the forms for payday loans and prepaid cards in November 2013 and July 2014. Our stakeholders were excited about new culture of working directly with designers, and the completion rate for the new forms has consistently averaged over 10 percentage points above those with the older design.
The biggest success of these releases was establishing a deepening trust from stakeholders in our team’s ability to improve the consumer experience, and we now had the freedom to recommend which projects we should work on next.
The obvious next step was to push our new design to the existing complaint forms, but doing so would require months of work from the developers of the CRM vendor, who already had a long backlog of change requests and overdue upgrades. While I continued to advocate for these updates, our team focused our day-to-day work on improving the landing page for consumers who are interested in submitting a complaint.
We had conducted several rounds of usability testing during the redesign of the complaint forms, and during those sessions we noticed a number of issues with the design of the landing page at the time.
We found that test participants were likely to select a complaint form without reading any other part of the page, which led them to complete the form without knowing what to expect afterwards, and often assume that the CFPB would provide a dedicated caseworker for their complaint (it does not). Worse, some consumers would quickly select the incorrect form for their complaint, resulting in the complaint being forwarded to a company that is not at fault (this is particularly common with issues involving credit reporting, for which it’s not always clear whether the complaint is about the credit reporting agency or the company that provided the data to the credit agency).
Page analytics and conversations with our intake staff supported this finding, so we developed a new design to slow people down and included additional information about each product type to help consumers get to the right place.
We decided to move the detailed, step-by-step review of the complaint process to a separate page, replacing it with a single paragraph introduction that would be easier to scan. We also added a new page explaining exactly how we use the data submitted in complaints, including the specific fields that we publish in our public Consumer Complaint Database. During the design process for these pages, our team tested the layout and content with patrons in the computer lab of a public library in Austin’s East Downtown neighborhood.
Over the following months, we refined designs for the mobile and tablet breakpoints of the complaint form, and I began having conversations with senior stakeholders about requirements for a “unified form” project, that would create a single form for all complaint types. During this process, the Technology Portfolio Manager and I continued to voice concerns about the efficiency and code quality of our CRM vendor, though we accepted that a unified experience for all products would be a huge benefit for consumers, even with the same vendor managing the back end.
The primary benefits to combining the forms were that (a) we would be able to make changes and optimize the experience for all of the product types simultaneously, reducing costs and development time, and (b) consumers would be able to submit complaints about problems that involve multiple companies in different industries (e.g., your student loan servicer and the bank that holds your checking account, or your credit card company and all three major credit reporting agencies).
The new-from-scratch nature of the project also held the promise of allowing us to support a number of long-desired improvements, including responsive design, support for multiple languages, the ability to save progress and return later, and an “expert view” that could allow our call center staff to use the web form for accepting complaints over the phone, with a layer of additional information for necessary prompts and knowledgebase content.
Of course, including all of these features in the scope for the first release would be a recipe for failure, so I planned a user-centered process for defining the ideal scope and requirements for the initial release.
Each month, our design team, which now included a business analyst, would explore the operational needs for a set of core functionalities (e.g., company identification), and would begin designing wireframes and interactive prototypes based on those needs. We met with an “advisory team” of stakeholders from different operational divisions every Wednesday to talk about our findings and show our latest designs, and we conducted usability testing every month to test the latest designs with consumers who had recently had a significant problem with a financial product or service.
After adjusting for what we learned from each round of usability testing, we presented a monthly demo of our latest work to anyone who was interested in attending, usually over 40 people from across the organization. Because the stakeholders on our advisory team had been seeing the work every week, they were able to answer questions during the demos about how the design decisions would affect their operational areas (again, no one benefits from a big reveal).
Each monthly demo would kick off the process of writing formal requirements with the CRM team for that set of operational needs. This allowed our design team to use the feedback gained from usability testing to help prioritize different features and functionality against the vendor’s estimates for levels of effort.
This approach turned out to be extremely effective in an unexpected way: because our stakeholders had already seen interactive prototypes of what we considered to be an ideal design for the service, they were more concerned when our vendor claimed that key functionality couldn’t be completed on our existing platform. After three months of prototyping, usability testing, live demos, and refining requirements, our stakeholders agreed to replace the existing CRM platform with a new system that would be capable of building what we had designed.
The new system launched in April 2017 at consumerfinance.gov/complaint