Step 1 – Import File
The creditor uploads consumer account data using:
- Add New Accounts
- Add Accounts + CFPB
Result
The import file enters validation and processing workflows.
Step 2 – File Validation & Processing
The platform validates and processes uploaded account data.
Validation Includes
- Required field validation
- Consumer PII duplication checks
- Original account duplication checks
- Dispute reason validation
- No-pay reason validation
- Paid account validation
- Communication data validation
Processing Outcomes
- Validated accounts are:
- Matched to consumer records
- Appended with eligible pay-term offers
- Prepared for Consumer EcoPortal delivery
- Routed into communication workflows
- Generated with CFPB Validation Letters when applicable
Failure Scenarios
- Missing required fields
- Duplicate account records
- Invalid consumer data
- Invalid communication data
- Invalid account status
Step 3 – Deliver Account to Consumer Portal
After validation and processing, the platform delivers:
- Consumer account data
- Negotiation offers
- Associated account metadata
into the consumer’s secure portal.
Key Concept
Account delivery occurs before notification delivery.
The Consumer Portal serves as the system of record for consumer account access, offer visibility, and negotiation activity.
Step 4 – Consumer Notification Decision Engine
After account delivery, the platform evaluates whether outbound notifications may be sent.
Decision Path A – Communication Profile Exists
Question
Does the consumer have an active Communication Profile?
If Yes
The platform uses stored consumer preferences and consent settings.
Notification Rules
Notifications may be sent according to:
- SMS preferences
- Email preferences
- Preferred communication channels
- Consent settings
- Frequency preferences
Examples
- SMS only → Send text notification
- Email only → Send email notification
- SMS and Email → Send both
Decision Path B – No Communication Profile Exists
Question
Does the consumer have a Communication Profile?
If No
The platform uses creditor-supplied contact information from the imported account.
- Mobile phone number
- Email address
Step 5 – PII Opt-Out Compliance Check
Before any fallback notification is sent, the platform validates contact information against the PII Opt-Out Registry.
Compliance Validation
- Is the email address opted out?
- Is the mobile phone number opted out?
The platform may send:
- SMS notifications
- Email notifications
The platform suppresses notifications for that communication method.
Examples
- Mobile opted out → No SMS
- Email opted out → No Email
- Both opted out → No outbound notification
Important Compliance Rule
The platform must never send outbound communications to contact methods listed on the consumer’s PII Opt-Out Registry.
Consumer communication preferences and opt-out settings always override creditor-uploaded contact information.Last modified on June 1, 2026
