CONSUMER FINANCIAL PROTECTION BUREAU
Strategic plan, budget,
and performance
plan and report
March 2014
. Table of Contents
Letter from the Director.........................................................................................................4
Overview of the CFPB............................................................................................................ 6
Plan Overview.......................................................................................................................10
Budget Overview.................................................................................................................. 11
Budget by strategic goal..................................................................................... 12
Budget by program............................................................................................
13
FTE by program................................................................................................. 15
Budget by object class........................................................................................ 16
Summary of key investments............................................................................
17
Budget authority............................................................................................... 20
Goal 1......................................................................................................................................23
Outcome 1.1........................................................................................................25
Outcome 1.2...................................................................................................... 30
Outcome 1.3......................................................................................................
30
Goal 2...................................................................................................................................... 41
Outcome 2.1.......................................................................................................43
Outcome 2.2.......................................................................................................50
Goal 3......................................................................................................................................62
Outcome 3.1.......................................................................................................63
Outcome 3.2...................................................................................................... 66
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
Goal 4...................................................................................................................................... 71
Outcome 4.1.......................................................................................................72
Outcome 4.2......................................................................................................76
Outcome 4.3...................................................................................................... 80
Outcome 4.4..................................................................................................... 84
Appendix A............................................................................................................................
87
Appendix B: Organizational chart......................................................................................90
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. Message from
Richard Cordray
Director of the CFPB
Last year, we delivered the first integrated view of the Consumer Financial Protection Bureau’s
(CFPB’s or Bureau’s) Strategic Plan for fiscal years 2013–2017, as well as the Budget and
Annual Performance Plan and Report. This holistic presentation of the Bureau’s goals, budget,
performance measures, and accomplishments achieves our goal to increase transparency and
make information accessible to American consumers and other key stakeholders, including
Congress as well as Federal, and state agencies.
Building on the established integrated framework, we are presenting a comprehensive review
of progress that the CFPB achieved in fiscal year (FY) 2013 across its four established Strategic
Goals for FY 2013–2017. The document also contains the Bureau’s most current view of budget
projections for FY 2014–2015 and corresponding performance measures across the full set of
performance goals.
To share a few highlights, in FY 2013, the CFPB:
§§ Launched 160 supervision activities at various financial institutions;
§§ Handled approximately 144,000 consumer complaints about credit cards, mortgages,
and other financial products;
§§ Provided digital content, materials, and decision tools to over 1.9 million consumers;
§§ Established key infrastructure for the Civil Penalty Fund to distribute payments to
identified victims.
These accomplishments clearly signal that the Bureau maintains an unwavering focus on
leveraging available resources wisely and carefully. The CFPB remains committed to data-driven
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
and objective decision-making processes, as well as the robustness, completeness, and reliability
of performance information.
Congress created this independent bureau within the Federal Reserve System as part of the
Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 in direct response to
a severe financial crisis. The Bureau is dedicated to fulfilling its consumer protection mission
by providing research insights, making sound policy, delivering informational resources, and
overseeing financial markets. The CFPB will continue to work closely with Congress, businesses,
consumer advocates, and its Federal, state, and local partners to strengthen accountability for
consumer financial protection.
Sincerely,
Richard Cordray, Director
March 2014
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. Overview of the CFPB
The Bureau of Consumer Financial Protection, known as the Consumer Financial Protection
Bureau (CFPB), was established on July 21, 2010 under Title X of the Dodd-Frank Wall Street
Reform and Consumer Protection Act Public Law No. 111-203 (Dodd-Frank Act). The CFPB was
established as an independent bureau within the Federal Reserve System. The Bureau is an
Executive agency as defined in Section 105 of Title 5, United States Code.
The Dodd-Frank Act authorizes the CFPB to exercise its authorities to ensure that, with respect
to consumer financial products and services:
1. Consumers are provided with timely and understandable information to make responsible
decisions about financial transactions;
2. Consumers are protected from unfair, deceptive, or abusive acts and practices and from
discrimination;
3. Outdated, unnecessary, or unduly burdensome regulations are regularly identified and
addressed in order to reduce unwarranted regulatory burdens;
4. Federal consumer financial law is enforced consistently in order to promote fair
competition; and
5. Markets for consumer financial products and services operate transparently and
efficiently to facilitate access and innovation.
Under the Dodd-Frank Act, on the designated transfer date, July 21, 2011, certain authorities and
functions of several agencies relating to Federal consumer financial law transferred to the CFPB
in order to accomplish the above objectives.
These authorities were transferred from the Board
of Governors of the Federal Reserve System (Board of Governors), Office of the Comptroller of
the Currency (OCC), Office of Thrift Supervision (OTS), Federal Deposit Insurance Corporation
(FDIC), National Credit Union Administration (NCUA), and the Department of Housing and
Urban Development (HUD). In addition, Congress vested the Bureau with authority to enforce
in certain circumstances the Federal Trade Commission’s (FTC) Telemarketing Sales Rule and
its rules under the FTC Act, although the FTC retains full authority over these rules. The Dodd6
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
Frank Act also provided the CFPB with certain other Federal consumer financial regulatory
authorities.
Our organization
Under the Dodd-Frank Act, the Secretary of the Treasury was responsible for establishing the
CFPB and performing certain functions of the Bureau until a Director of the CFPB was in place.
The Bureau’s day-to-day operations were managed by the Special Advisor to the Secretary of the
Treasury for the Consumer Financial Protection Bureau until January 4, 2012, when President
Obama recess appointed Richard Cordray as the first Director of the CFPB. Subsequently, the
U.S. Senate confirmed the appointment of Richard Cordray on July 16, 2013, and Director
Cordray was sworn in as the first Senate confirmed Director of the CFPB on July 17, 2013.
To accomplish its mission, the CFPB is organized into six primary divisions:
1. Consumer Education and Engagement: works to empower consumers with the
knowledge, tools, and capabilities they need in order to make better-informed financial
decisions by engaging them in the right moments of their financial lives, while addressing
the unique financial challenges faced by four specific populations.
2. Supervision, Enforcement and Fair Lending: ensures compliance with Federal
consumer financial laws by supervising market participants and bringing enforcement
actions when appropriate.
3. Research, Markets and Regulations: conducts research to understand consumer
financial markets and consumer behavior, evaluates whether there is a need for regulation,
and determines the costs and benefits of potential or existing regulations.
4. Legal Division: ensures the Bureau’s compliance with all applicable laws and provides
advice to the Director and the Bureau’s divisions.
5. External Affairs: manages the Bureau’s relationships with external stakeholders
and ensures that the Bureau maintains robust dialogue with interested stakeholders to
promote understanding, transparency, and accountability.
6. Operations: builds and sustains the CFPB’s operational infrastructure to support the
entire organization and hears directly from consumers about challenges they face in the
marketplaces through their complaints, questions, and feedback.
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. Our mission
The CFPB is a 21st century agency that helps consumer finance markets work by making rules
more effective, by consistently and fairly enforcing those rules, and by empowering consumers
to take more control over their economic lives.
Our vision
If we achieve our mission, then we will have encouraged the development of a consumer finance
marketplace
§§ where customers can see prices and risks up front and where they can easily make product
comparisons;
§§ in which no one can build a business model around unfair, deceptive, or abusive practices;
§§ that works for American consumers, responsible providers, and the economy as a whole.
We will achieve our mission and vision through:
Data-driven analysis
The CFPB is a data-driven agency. We take in data, manage it, store it, share it
appropriately, and protect it from unauthorized access. Our aim is to use data
purposefully, to analyze and distill data to enable informed decision-making
in all internal and external functions.
Innovative use of technology
Technology is core to the CFPB accomplishing its mission. This means
developing and leveraging technology to enhance the CFPB’s reach, impact,
and effectiveness.
We strive to be recognized as an innovative, 21st century
agency whose approach to technology serves as a model within government.
Valuing the best people and great teamwork
At the CFPB, we believe our people are our greatest asset. Therefore, we invest
in world-class training and support in order to create a diverse and inclusive
environment that encourages employees at all levels to tackle complex challenges.
We also believe effective teamwork extends outside the walls of the CFPB. We
seek input from and collaborate with consumers, industry, government entities,
and other external stakeholders.
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
We aim to embody the following values in everything we do:
Service
Our mission begins with service to the consumer and our country. We serve
our colleagues by listening to one another and by sharing our collective
knowledge and experience.
Leadership
Fostering leadership and collaboration at all levels is at the core of our success.
We believe in investing in the growth of our colleagues and in creating an
organization that is accountable to the American people.
Innovation
Our organization embraces new ideas and technology. We are focused on
continuously improving, learning, and pushing ourselves to be great.
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. Plan overview
Our strategic plan articulates four goals
Goal 1
Prevent financial harm to consumers while promoting good practices that
benefit them.
Goal 2
Empower consumers to live better financial lives.
Goal 3
Inform the public, policy makers, and the CFPB’s own policy-making with
data-driven analysis of consumer finance markets and consumer behavior.
Goal 4
Advance the CFPB’s performance by maximizing resource productivity and
enhancing impact.
In support of each goal we outline
Budget
Outcomes
Desired outcomes that further define the focus of our work.
Strategies &
investments
Strategies and investments that lay out the actions we will take to
accomplish our outcomes.
Performance
goals
10
Resource allocations we will make in order to achieve our goals.
Specific, measurable goals we will use to assess our progress along with
associated measures and indicators.
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. Budget overview
The CFPB’s operations are funded principally by transfers made by the Board of Governors of
the Federal Reserve System from the combined earnings of the Federal Reserve System, up to
the limits set forth in the Dodd-Frank Act. The Director of the CFPB requests transfers from
the Federal Reserve System in amounts that he has determined are reasonably necessary to
carry out the Bureau’s mission without exceeding the limits in the Dodd-Frank Act. Transfers
through FY 2013 are capped at set percentages of the total 2009 operating expenses of the
Federal Reserve System. In fiscal years 2014 and beyond, the cap is adjusted annually based on
the percentage increase in the employment cost index for the total compensation for State and
local government workers published by the Federal Government.
Transfers from the Federal
Reserve System are capped at $608.4 million for FY 2014. For FY 2015, the funding cap is
currently estimated to be $618.7 million. Funds transferred from the Federal Reserve System
are deposited into the Bureau of Consumer Financial Protection Fund (Bureau Fund), which is
maintained at the Federal Reserve Bank of New York.
Pursuant to the Dodd-Frank Act, the CFPB is also authorized to collect and retain for specified
purposes civil penalties obtained from any person for violations of Federal consumer financial
laws.
The CFPB generally is authorized to use these funds for payments to the victims of
activities for which civil penalties have been imposed, and may also use the funds for consumer
education and financial literacy programs under certain circumstances. Funds collected by the
CFPB under this authority are deposited into the Consumer Financial Civil Penalty Fund (Civil
Penalty Fund) maintained at the Federal Reserve Bank of New York.
Bureau Fund
The CFPB FY 2014 and FY 2015 budget estimates included in this report will support the
operations of the Bureau while it continues to grow and mature as a Federal agency. These
resources will enable the Bureau to continue to fulfill its statutory obligations and its mission to
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
make rules more effective, by consistently and fairly enforcing those rules, and by empowering
consumers to take more control over their financial lives.
The FY 2015 budget estimate of $583.4 million is 2.4% above the FY 2014 budget level of
$569.8 million. The budget supports ongoing operations, additional examiner staff, and key
investments, especially in developing the consumer response system and other IT infrastructure
projects, to achieve the four strategic goals outlined in this plan.
Budget by strategic goal
Goal 1
Prevent financial harm to consumers while promoting good practices that
benefit them.
Goal 2
Empower consumers to live better financial lives.
Goal 3
Inform the public, policy makers, and the CFPB’s own policy-making with
data-driven analysis of consumer finance markets and consumer behavior.
Goal 4
Advance the CFPB’s performance by maximizing resource productivity and
enhancing impact.
The data below provides a view of our budgetary resources by strategic goal. The proportion of
funding across all goals is expected to remain relatively constant through FY 2015. Activities
related to regulation, supervision, and enforcement activities, which are included in Goal 1,
represent the largest proportion of the budget at 47% and primarily support the continued
growth of the regional supervision and examination workforce as the CFPB moves towards
steady-state levels.
Other key investments in FY 2014 and FY 2015 are devoted to activities
under Goal 2, which include expanding capacity and systems to improve the handling and
processing of consumer complaints as well as helping consumers understand the costs, risks,
and trade-offs of financial decisions through financial education outreach tools, and support.
The proportion of funding for Goal 3 and 4 decreases through FY 2015 as research and market
monitoring functions as well as investments in human capital and internal infrastructure begin
reaching maturity.
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. TABLE 1:
Budget by strategic goal
FY 2013
%
FY 2014
%
FY 2015
%
Goal 1
$231,428,989
43%
$266,316,370
47%
$275,217,834
47%
Goal 2
$111,886,226
21%
$123,560,303
22%
$133,662,241
23%
Goal 3
$58,521,214
11%
$58,436,996
10%
$56,022,179
10%
Goal 4
$136,896,529
25%
$121,531,078
21%
$118,515,946
20%
$538,732,958
100%
$569,844,747
100%
$583,418,201
100%
Total
* FY 2014 and FY 2015 estimates are based on the best available information at the time the budget was
prepared and are subject to revision.
** FY 2013 amounts reflect obligations incurred and include upward adjustments to prior year obligations.
Budget by program
Over the FY 2014–FY 2015 time period, the budget provides additional resources for all
programs. Supervision, Enforcement, and Fair Lending primarily drive the increases in funding
over this two-year window to support additional staff and systems development, such as e-tools
that enhance the ability to assess compliance with Federal consumer financial laws.
Consumer Response realizes a significant increase in funding in FY 2014 and FY 2015 as it
continues to process increased volumes of complaints and seek new ways to improve existing
processes to make them as efficient, effective, and easy-to-use as possible. From FY 2012 to
FY 2013, the volume of consumer complaints handled by the Bureau grew by 94.6%. By FY 2015,
the Bureau expects the number of complaints to continue to grow as consumers increasingly
utilize the variety of tools, programs, and initiatives that provide targeted, meaningful, and
accessible assistance and information.
This projected increase in handling complaints is
described in more detail under the discussion of Goal 2.
Within Operations, personnel and investments in technology drive the rise in funding in
FY 2014. In FY 2015, increased funding to support staffing will continue, but will be partially
offset by technological developments entering a more steady state.
In addition to enterprise-wide administrative and operational costs (e.g. building space, rent,
utilities), Centralized Services in FY 2014 also includes one-time investments supporting a
relocation of CFPB employees to a temporary building during the second half of FY 2014 in
preparation of major building renovations to the current D.C.
headquarters building. Funding
for the building renovations is included in FY 2013 Centralized Services as the result of
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. an inter-agency agreement between the General Services Administration (GSA) and the
CFPB. The current headquarters building has not undergone a significant renovation since
it was constructed in 1976. Planned renovations include replacement of major utilities and
infrastructure such as the roof, building enclosure, and heating, water, and electrical systems.
Once the Bureau moves to the temporary location, it expects to see cost reductions in FY 2015
related to the discontinuation of regular maintenance and operating costs of the current D.C.
headquarters during the relocation.
Funding changes for Consumer Education and Engagement as well as Research, Markets, and
Regulations are due to the variety of key investments and their respective life cycle stages. These
are detailed in the Summary of Key Investments table and in each goal discussion.
TABLE 2:
Budget by program
FY 2013
FY 2014
FY 2015
$5,234,704
$4,515,983
$4,711,724
Operations
$54,171,404
$68,684,285
$69,744,184
Operations Consumer Response
$39,586,117
$68,782,620
$73,072,513
Consumer Education
and Engagement
$22,263,284
$31,589,071
$38,588,426
Research, Markets,
and Regulation
$32,895,564
$47,815,380
$42,556,406
Supervision,
Enforcement, and Fair
Lending
$105,568,127
$165,342,969
$174,770,999
Legal
$10,308,644
$15,508,793
$16,891,971
$4,833,964
$6,909,993
$7,807,621
$1,241,727
$3,310,693
$3,611,304
$262,629,424
$157,384,960
$151,663,053
$538,732,958
$569,844,747
$583,418,201
Office of the Director
External Affairs
Other Programs*
Centralized Services**
Total
* Other Programs include the Director’s Financial Analyst Program, Ombudsman, and Administrative Law
Judges.
** Centralized Services include the cost of certain administrative and operational services provided centrally to
other programs (e.g., building space, utilities, and IT-related equipment and services).
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
FTE by program
The table below reflects full-time equivalent employees  (FTEs) by program. The Bureau will
continue to expand capacity over FY 2013 levels in order to successfully achieve its strategic
goals. More than 45% of the growth in staff over the next two fiscal years will support the
Supervision, Enforcement, and Fair Lending Division, while the Bureau continues to staff
its regional examination workforce. The Bureau will also continue to increase FTE levels in
Consumer Response in order to ensure sufficient capacity to handle the increasing volume
of consumer complaints.
Planned staffing in the Operations program offices will continue
to support the Bureau’s development of the internal infrastructure, critical to creating and
maintaining a high-performing organization. More detail on personnel investments is included
in each discussion by goal.
TABLE 3:
FTE by program
Programs
FY 2013
FY 2014
FY 2015
27
27
28
Operations
221
304
325
Consumer Response
134
191
223
55
73
77
Research, Markets, and Regulations
107
147
156
Supervision, Enforcement, and Fair
Lending
527
742
834
Legal
51
70
76
External Affairs
29
44
47
Other Programs
11
26
30
1,162
1,624
1,796
Office of the Director
Consumer Education and
Engagement
Total
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. Budget by object class
The table below provides a view of the CFPB’s budget by spending category or object
classification. Personnel compensation and benefits represent the largest increases over the
two-year horizon as the Bureau continues to hire additional personnel as described above. Total
travel expenses are also projected to increase over time as the examination workforce continues
to grow and conduct various examination activities across the country. The growth in funds
allocated to rents, communications, and miscellaneous charges represent the costs related to
temporarily relocating CFPB employees during the renovation of the D.C.
headquarters, which is
scheduled to begin in the latter part of FY 2014.
The FY 2014 increase in funding for other for “Other Contractual Services” and “Equipment”
indicates various technology investments that support the continued development of IT
infrastructure throughout the Bureau. Lower budget estimates in these categories in FY 2015
reflect the short-term nature of these investments.
TABLE 4:
Budget by object classification
Object Classification
FY 2013
FY 2014
FY 2015
$143,341,164
$203,079,639
$234,551,540
Personnel Benefits
$48,998,214
$69,575,962
$79,940,993
Benefits to Former
Personnel
$70,856
$223,381
$282,990
Travel and
Transportation of
Persons
$14,484,205
$22,555,217
$26,129,269
Transportation of
Things
$154,148
$25,000
$30,000
Rents,
Communications, and
Misc Charges
$5,611,501
$12,775,278
$17,622,000
Printing and
Reproduction
$2,227,637
$2,007,011
$2,943,411
$136,790,301
$215,081,450
$185,154,321
$4,659,968
$4,806,891
$4,934,321
Personnel
Compensation
Other Contractual
Services
Supplies and Materials
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. Object Classification
Land and Structures
Interest and Dividends
Total
FY 2014
FY 2015
$31,586,601
$39,714,918
$31,829,356
$150,805,839
-
-
$2,523
-
-
$538,732,958
Equipment
FY 2013
$569,844,747
$583,418,201
Summary of key investments
Since FY 2013, the CFPB has expanded the activities associated with key investments in order to
achieve its strategic goals. The table below details the funding levels for the Bureau’s key nonpersonnel investments by outcome. Spending for certain investments, such as IT infrastructure,
supervision compliance tools, e-law tools for supervision and enforcement activities, and
operational improvements in the consumer response system, will increase in FY 2014, but
decrease in FY 2015 as start-up costs decline. Spending on investments, such as audits of the
Bureau, the consumer response contact center, and litigation support, will continue at similar
levels in FY 2014 and FY 2015.
Other investments, such as the consumer experience program
and underserved populations research and innovations, reflect funding at increased levels in
FY 2014 and FY 2015 as the CFPB continues its work to promote a healthy consumer financial
marketplace and provide consumers with the information and tools to improve their financial
lives. Key investments are presented in more detail in the discussion of each goal.
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. TABLE 5:
Key investments (in millions)
Outcome
Key Investment Description
1.1
Disclosure, design, testing and
implementation
1.2, 1.3
FY 2015
$0.4
$3.4
$0.3
Examiner training and travel
$12.1
$21.9
$24.2
$5.0
$7.5
$4.5
E-law tools and support
$4.6
$12.6
$8.4
Litigation support
$2.1
$3.0
$3.5
Mortgage servicing project
—
$3.0
$3.0
Supervision and examination system
—
$1.1
$1.1
$18.1
$22.7
$27.8
Consumer response operational and
program support
$3.7
$5.1
$2.6
Optimizing CFPB communication
and consumer engagement channels
$ 0.4
$2.7
$1.4
Consumer response system - natural
language processing
—
$10.7
$8.1
Consumer experience program
$3.9
$5.6
$6.8
Consumer education campaigns
$1.7
$2.2
$2.5
Underserved and special
populations program
$0.9
$0.3
$0.9
Underserved and special
populations outreach
$0.7
$2.7
$7.6
Optimizing CFPB communication
and consumer engagement channels
$0.4
$0.8
—
—
$0.7
$0.2
Credit card database
$4.1
$3.0
$3.0
Other market data
2.2
FY 2014
Supervision compliance tool
2.1
FY 2013
$2.3
$1.4
$0.9
Consumer response system and
contact center support
Your money, your goals
3.1
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. Outcome
FY 2013
FY 2014
FY 2015
HMDA development and
implementation
$2.3
$3.0
$2.5
Evidence-based consumer financial
market research
$0.4
$1.7
$0.5
Mortgage database
$1.0
$1.1
$1.1
Compliance cost study
$2.0
—
—
Financial education research
$1.9
$1.2
$1.4
Underserved and special
populations research
$0.9
$2.1
$2.0
Consumer experience program
$0.8
$0.6
$0.6
Financial education innovations
$0.7
$1.0
$1.0
Evidence-based consumer financial
market research
$0.2
$2.5
$0.3
Financial education metrics
$0.1
$0.7
$1.4
—
$2.0
$2.0
Human capital shared services,
infrastructure, and operations
$8.6
$8.9
$9.7
Learning, leadership, and
organization development
facilitation and design
$4.4
$4.9
$4.2
Outreach, candidate recruiting, and
candidate selection support
$1.3
$3.8
$2.7
$31.9
$27.2
$19.4
Design and software development
support
$6.1
$5.6
$6.1
Cybersecurity
$3.5
$3.5
$3.1
Portfolio management
$0.2
$11.9
$11.6
Data infrastructure and analysis
3.2
Key Investment Description
$1.2
$1.5
$0.7
Know before you owe—mortgage
closing
4.1
4.2
19
Infrastructure
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. Outcome
Key Investment Description
4.3
FY 2014
FY 2015
Audits of the Bureau
$11.7
$6.8
$6.8
Financial management support
services
$6.2
$6.5
$5.9
Internal controls
$2.1
$1.5
$1.5
$145.1
—
—
Facilities agreements (occupancy)
$16.5
$18.7
$17.2
Facilities agreements (utilities,
security, other)
$11.3
$12.2
$5.9
Architecture and engineering
services for HQ building renovation
$5.1
—
—
Personnel security investigations
$1.1
$1.2
$1.4
Facilities agreements (occupancy) for
temporary space
—
$5.8
$10.0
Facilities agreements (utilities,
security, other) for temporary space
All
FY 2013
—
$10.1
$3.5
$19.4
$40.6
$39.3
$346.3
$297.0
$268.6
HQ building renovation
Other*
Total
* Includes administrative costs such as training, supplies, printing, transportation, and programmatic costs as
well as upward adjustments to prior year obligations.
Budget authority
Funding required to support the CFPB’s operations is obtained primarily through transfers
from the Board of Governors of the Federal Reserve System. Funding is capped at a set
percentage of the total 2009 operating expenses of the Federal Reserve System, subject to an
annual adjustment. Beginning in FY 2014, transfers to the Bureau are capped at 12 percent of
the Federal Reserve System’s operating expenses, but will be adjusted annually based on the
percentage increase in the employment cost index for total compensation for State and local
government workers published by the Federal Government as specified in the Dodd-Frank
Act. The inflation-adjusted transfer cap for FY 2014 is $608.4 million, and the transfer cap
for FY 2015 is currently estimated to be $618.7 million.
Funds transferred from the Federal
Reserve System to fund the operations of the Bureau are transferred into the Bureau Fund and
20
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. maintained at the Federal Reserve Bank of New York. The Bureau anticipates requesting less
than the transfer cap to fund operations in FY 2014 and FY 2015.
In addition to transfers from the Federal Reserve, a small portion of the CFPB’s budget
resources comes from receipts collected from interest on treasury securities and filing fees
pursuant to the Interstate Land Sales Full Disclosure Act of 1968 (ILSA). ILSA fees are
deposited into an account maintained by the Department of the Treasury and may be expended
for the purpose of covering all or part of the costs that the Bureau incurs to operate the ILSA
Program.
TABLE 6:
Bureau Fund (in millions)
Receipts
FY 2013
FY 2014
FY 2015
$518.4
$561.3
$583.0
$0.4
$0.4
$0.4
Unobligated Balances, start of year
$99.6
$88.1
$80.0
Recoveries of Prior Year Obligations
$8.8
—
—
Total Budgetary Resources
$627.2
$649.8
$663.4
Total Obligations
$538.7
$569.8
$583.4
Transfers from the Federal Reserve Board
Other Receipts
Civil Penalty Fund budget authority
The Dodd-Frank Act authorizes the CFPB to collect and retain for specified purposes civil
penalties obtained from any person in a judicial or administrative action under Federal
consumer financial laws. The CFPB maintains the Consumer Financial Civil Penalty Fund
(CPF) for this purpose.
Collections of civil penalties are deposited into the CPF, and such funds
are available for payments to victims of activities for which civil penalties have been imposed
under the Federal consumer financial laws and, if victims cannot be located or payments are
not practicable, the Bureau can use such funds for consumer education and financial literacy
programs. As directed by the Dodd-Frank Act, the CFPB maintains a separate account for these
funds at the Federal Reserve Bank of New York.
On May 7, 2013, the Bureau published the Civil Penalty Fund rule, 12 C.F.R. part 1075, a final
rule governing how the Bureau will administer funds in the CPF.
This rule states that the Civil
Penalty Fund Administrator will allocate funds to classes of eligible victims and, as appropriate,
21
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. to consumer education and financial literacy programs in accordance with a schedule published
by the Bureau on its website.
The CFPB collected $81.5 million in actual deposits by the end of FY 2013 and expects to collect
additional amounts during FY 2014. Of the amounts collected to date, the Bureau allocated
$26.4 million as published in the CPF annual report1. Approximately $13.0 million was allocated
to compensate harmed consumers and $13.4 million for consumer education and financial
literacy programs. Of the $13.4 million allocated to consumer education and financial literacy
programs, $4.5 million are planned to be obligated in FY 2014, $4.5 million in FY 2015, and
$4.4 million in FY 2016.
Additional information regarding allocations from the CPF is available at consumerfinance.gov.
TABLE 7:
Civil Penalty Fund (in millions)
Receipts
FY 2013
FY 2014
FY 2015
Collections
$49.5
$10.0
$0.3
Unobligated Balances, start of year
$32.0
$81.5
$74.0
Total Budgetary Resources
$81.5
$91.5
$74.3
—
$17.5
$4.5
Total Obligations
1 The Dodd-Frank Act requires the CFPB to publish an annual report of the Civil Penalty Fund.
The Civil Penalty
Fund Annual Report was published within the FY 2013 Financial Report of the Consumer Financial Protection
Bureau, which is available at www.consumerfinance.gov.
22
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. Goal 1
Prevent financial harm to consumers while
promoting good practices that benefit them.
TABLE 8:
Budget by program, goal 1
Goal 1
FY 2013
FY 2014
FY 2015
Office of the Director
$1,308,676
$1,128,996
$1,177,931
Research, Markets,
and Regulation
$9,183,078
$15,827,979
$13,746,198
$105,568,127
$165,342,969
$174,770,999
$3,711,112
$6,090,703
$6,776,617
External Affairs
$725,095
$1,036,499
$1,171,143
Other Programs
$613,303
$1,750,401
$1,980,440
$110,319,599
$75,138,823
$75,594,506
$231,428,989
$266,316,370
$275,217,834
Supervision,
Enforcement, and Fair
Lending
Legal
Centralized Services
Total
23
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. FIGURE 1: Almost every American family relies on one or more financial products 2
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
92%
45%
39%
30%
19%
Transaction
accounts
Mortgages
Credit card
balances
Vehicle loans
Education
loans
Prior to Congress enacting the Dodd-Frank Act, consumer financial protection had not been the
primary focus of any one Federal agency, and no agency could set the rules for the entire
financial market. The result was a system without sufficiently effective rules or consistent
enforcement of the law. The absence of such a regulating entity and corresponding rules
ultimately contributed to the 2008 financial crisis.
Consumer financial protection is the CFPB’s singular focus. The Dodd-Frank Act increased
accountability in government by consolidating consumer financial protection authorities that
had existed across seven different Federal agencies into one, the newly formed Consumer
Financial Protection Bureau.
These authorities include the ability to issue regulations under
more than a dozen Federal consumer financial laws. As provided in section 1021 of the DoddFrank Act, the purpose of the CFPB is to implement and enforce Federal consumer financial
laws consistently for the purpose of ensuring that all consumers have access to markets for
consumer financial products and services and that such markets are fair, transparent, and
competitive.
In addition, the Dodd-Frank Act gives the CFPB the authority to supervise and examine many
non-bank financial service providers previously unsupervised at the Federal level, such as
mortgage companies, payday lenders, private education lenders, and larger debt collectors and
consumer reporting companies. With the consolidation of existing and new authorities under
one roof, the CFPB is now focused and equipped to prevent financial harm to consumers while
promoting practices that benefit consumers across financial institutions.
2 Federal Reserve Board, “2010 Survey of Consumer Finances,” tables 13–10, 6–10 based on public data, last
updated 7/19/2012, http://www.Federalreserve.gov/econresdata/scf/scf_2010.htm (Last viewed 8/23/2012).
24
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
FIGURE 2: Financial institutions subject to CFPB supervisory authority for consumer financial protection
purposes
Large banks, thrifts, credit unions
& their affiliates
Certain nonbank institutions
Representing over $10 trillion in assets (~75% of
total industry)
Including companies engaged in mortgage
lending, brokering, and servicing; payday
lenders; private education lenders; and larger
participants of the consumer debt collection
and consumer reporting markets
Industry structure is always changing, and therefore, so too will the number of institutions that
fall under the CFPB’s supervisory authority. The CFPB is designed to be agile and adjust its
approach to supervising the financial industry in order to respond rapidly to changing consumer
needs.
The CFPB will accomplish its first goal by
achieving three outcomes
Outcome 1.1: Create, adopt, and administer regulations in order to
promote a consumer financial marketplace in which: (A) consumers
can understand the costs, benefits, and risks associated with consumer
financial products and services initially and over the term of the product or
service, and (B) consumers are not subject to deceptive, unfair, abusive, or
discriminatory practices.
Outcome leader: Associate Director of Research, Markets, and Regulations
This outcome will be accomplished through the following
strategies and investments:
Strategies
§§ Develop and maintain an efficient fact-based approach to developing, evaluating, revising,
25
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. and finalizing regulations.
§§ Develop a rule-writing team with highly advanced skills in relevant and specialized legal
and business areas.
§§ Work with consumers and industry stakeholders on developing regulations to implement
existing Federal consumer financial laws effectively.
§§ Leverage technology to continuously improve the efficiency and effectiveness of the Federal
rulemaking processes and procedures.
§§ Study electronic delivery of financial product disclosure information to consumers and
develop methods to facilitate electronic delivery that will provide benefits to consumers
and industry. Work with industry groups and other stakeholders to develop data standards
or build on existing standards to facilitate electronic delivery of financial products to
consumers, create new tools that help consumers understand the financial products they
buy, and reduce unwarranted regulatory burden for industry.
Investments
PERSONNEL
Continue to expand capacity to conduct rulemaking activities, provide interpretive guidance,
develop small business compliance guides and provide other implementation support, and
evaluate benefits and costs of potential rules.
DISCLOSURE DESIGN, TESTING, AND IMPLEMENTATION
Continue to obtain and use expertise in disclosure design and disclosure usability testing.
Qualitative research, such as one-on-one cognitive interviews, enables the Bureau to put forward
proposed forms which consumers are more likely to be able to navigate and comprehend. The
Bureau will also integrate these mortgage disclosure requirements under the Truth in Lending
Act and Real Estate Settlement Procedures Act.
26
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. We will assess our progress through the following three
performance goals:
Performance goal 1.1.1: Complete consumer protection related
rulemakings within nine months of receipt of final public comments.
The Bureau has made it a priority to ensure that it puts consumer protection regulations into
place, including those implementing statutory requirements, in a timely manner. For this reason,
the Bureau believes that completion of its own regulatory proposals within nine months of the
close of the public comment period is a good measure of whether it is meeting this goal.
PERFORMANCE MEASURE
The percentage of proposed rulemakings, conducted solely by the CFPB, finalized or
otherwise resolved within nine months of the due date for receipt of final public comments. 3
TABLE 9:
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
75%
75%
75%
Actual
100%
88%
NA
NA
PROGRESS UPDATE AND FUTURE ACTION
In FY 2013, the Bureau finalized a number of mortgage rules it proposed in FY 2012 to
implement consumer protection provisions enacted by the Dodd-Frank Act. For example, in
January 2013, the Bureau issued mortgage servicing rules under the Truth in Lending Act
(TILA) and the Real Estate Settlement Procedures Act (RESPA), and issued a final rule under
the TILA concerning loan originators’ licensing and registration, training, screening, and
compensation practices.
In addition, the Bureau finalized rules amending Regulation B to
implement the Dodd-Frank Act’s disclosure and delivery requirements for copies of appraisals
and other written valuations under the Equal Credit Opportunity Act (ECOA). The Bureau also
issued a final rule amending Regulation Z to implement the Dodd-Frank Act’s changes to the
Home Ownership and Equity Protection Act (HOEPA) expanding the scope of HOEPA coverage
and adding new consumer protections. This rule also implemented additional Dodd-Frank
requirements relating to homeownership counseling requirements under the RESPA and the
TILA.
All of these rules were based on the Bureau’s proposals issued in summer 2012. By issuing
3 This measure does not include interagency rulemakings, rulemakings inherited from the Federal Reserve Board,
and rulemakings on which the Bureau expects to do further quantitative research following the receipt of public
comments.
27
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. these and other final rules in January 2013 and meeting its statutory deadlines in addition to the
strategic goals, the Bureau also demonstrated its commitment to timely issuance of regulations.
During FY 2013, the Bureau also issued a proposed and final rule modifying earlier remittances
regulations that it had issued in 2012.4 In addition, the Bureau issued a number of clarifying and
technical amendments to the January 2013 mortgage rules. Going forward, early in FY 2014, the
Bureau will finalize its proposed rulemaking to integrate certain mortgage disclosures under the
RESPA and the TILA.
Performance goal 1.1.2: Complete all five-year regulation assessments on
schedule.
Section 1022(d) of the Dodd-Frank Act requires the CFPB to assess each significant rule the
Bureau adopts and publish a report of the assessment within five years of the effective date. The
assessment addresses, among other factors, the rule’s effectiveness in meeting the purposes and
objectives of the Dodd-Frank Act, Title X and the specific goals the Bureau states for the rule.
PERFORMANCE MEASURE
The percentage of five-year regulation assessments completed on schedule.
Targets
FY 2012: N/A
FY 2013: Develop a plan for meeting a pre-rule baseline
FY 2014: Develop strategies to best isolate the effects of rules
FY 2015: Begin collection and analysis of relevant quantitative and qualitative information.
Actuals
FY 2013: The Bureau began identifying existing data that may be useful for establishing
baselines and for analysis of potential changes from those baselines, identifying gaps in the
necessary data, and planning for the acquisition of additional data to fill those gaps.
4 This rule amended the Bureau’s February 2012 final remittance rule, which finalized a rulemaking initiated by the
Federal Reserve Board.
28
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. PROGRESS UPDATE AND FUTURE ACTION
The Bureau’s first five-year assessments will be due in 2018. The Bureau will in FY 2014 develop
strategies to best isolate the effects of rules to enable the Bureau to conduct before-and-after
reviews of certain rules.
Performance goal 1.1.3: Ensure that all rulemakings are informed
by public outreach processes, such as Small Business Regulatory
Enforcement Fairness Act (SBREFA) panels and consumer and
industry roundtables.
The Regulatory Flexibility Act, as amended by SBREFA and the Dodd-Frank Act, requires
the Bureau to convene a Small Business Review Panel before proposing a rule that will have a
significant economic impact on a substantial number of small entities. Other public outreach
efforts, such as meetings with consumers and industry stakeholders in the development of a
proposal, inform and otherwise assist the Bureau in crafting more effective rules. The Bureau is
also interested in exploring ways to increase general consumer involvement in the rulemaking
process.
PERFORMANCE MEASURE
The percentage of significant consumer protection related, notice-and-comment
rulemakings informed by public outreach processes
TABLE 10:
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
100%
100%
100%
Actual
100%
100%
NA
NA
PROGRESS UPDATE AND FUTURE ACTION
In January 2013, the CFPB finalized a number of proposed mortgage-related rules to implement
consumer protection changes required by the Dodd-Frank Act.
Those rules were informed
in several cases by Small Business Review Panel meetings with small entities that had been
conducted as required by SBREFA in 2012, as well as various other roundtables and meetings
held both before and after the issuance of the proposed rules. In FY 2013, the CFPB also
issued several proposed rules to amend, modify, or supplement its mortgage-related rules.
Those proposals were informed by ongoing public outreach efforts to industry stakeholders
and consumer advocates to monitor implementation issues in connection with the January
2013 mortgage rules, including a number of consumer and industry stakeholder roundtables
29
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. and meetings and staff participation in numerous external events. These outreach efforts
provided stakeholders an opportunity to provide input and discuss any issues presented by
the implementation of the mortgage rules or other matters for the Bureau to consider as it
formulated additional proposals. The CFPB also encouraged all stakeholders to submit formal
written comments on its proposals.
In addition to conducting outreach efforts for mortgage-related rules, the CFPB held a number
of other consumer and industry stakeholder outreach events and meetings in FY 2013 as it
continued to consider and develop future consumer protection rules. In anticipation of possible
future rulemaking or policy efforts, the Bureau held roundtables related to debt collection
practices and plans to issue an advance notice of proposed rulemaking in FY 2014 seeking
additional information from the public.
The CFPB intends to continue to undertake its public
outreach efforts to consumers and industry stakeholders as it considers topics for other possible
future consumer protection related rules in FY 2014. For example, the Bureau will engage with
the public and convene a Small Business Review Panel pursuant to SBREFA on a proposed rule
involving the Home Mortgage Disclosure Act.
Outcome 1.2: Supervise institutions to foster compliance with Federal
consumer financial laws, promote a fair consumer financial marketplace,
and prevent unlawful discrimination.
Outcome 1.3: Enforce Federal consumer financial laws and hold violators
accountable.
Outcome leader: Associate Director of Supervision, Enforcement, and Fair Lending
These outcomes will be accomplished through the following
strategies and investments:
Strategies
§§ Acquire and analyze qualitative and quantitative information and data pertaining to
consumer financial product and service markets and companies.
§§ Focus resources on institutions and their product lines that, based on their size, nature of
the product, and field and market intelligence, pose the greatest risk to consumers.
§§ Implement a framework for sharing information, coordinating activity, and promoting best
practices with fellow financial institution supervisory and law enforcement agencies to
30
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. ensure the most effective use of regulatory resources.
§§ Implement internal policies that facilitate the integration of the Bureau’s supervision,
enforcement, and fair lending functions.
§§ Continue to develop a technology solution for coordinating supervisory information,
capable of recording, storing, tracking, and reporting information on the CFPB’s
supervisory process.
§§ Continue implementing a tool capable of reviewing loan and deposit portfolios for
compliance with Federal consumer financial laws.
Investments
PERSONNEL
Hire additional staff to expand the Bureau’s capacity to focus on risks to consumers in the
policies and practices of consumer financial providers; analyze available data on the activities
of providers, on the markets in which they operate, and on the risks to consumers; implement
and enforce Federal consumer financial laws consistently for both bank and nonbank consumer
financial companies; and investigate and take actions to address potential violations of
consumer laws.
EX AMINER TRAINING AND TRAVEL
Support the development and delivery of training courses that are essential to examiner
commissioning and to maintaining a highly effective workforce. Also support the travel
requirements of the Bureau’s distributed workforce in order to effectively carryout its
supervision program.
SUPERVISION COMPLIANCE TOOL
Automate data analysis in order to review loan files more thoroughly, use supervision resources
more efficiently, and streamline the on-site portion of the exam. This tool will improve the
Bureau’s ability to assess compliance with Federal consumer financial laws, including fair
lending laws, and assess and detect risks to consumers.
E-L AW TOOLS AND SUPPORT
Maintain and increase capacity of electronic tools that obtain, process, and analyze evidence
received in enforcement investigations, enabling the Bureau to bring enforcement actions to
address violations of Federal consumer financial laws more efficiently.
31
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. LITIGATION SUPPORT
Employ standard investigatory tools to compel documents and testimony and to seek injunctive
and monetary remedies through civil actions or administrative proceedings. These functions
require the use of services such as expert witnesses, court reporters, and transcription services.
MORTGAGE SERVICING PROJECT
Lay the groundwork for the development of systems to assist consumers during the loan
modification process and collect and analyze information on loan servicer performance.
Investments will inform the CFPB’s efforts, particularly in the development of evaluative
materials.
SUPERVISION AND EX AMINATION SYSTEM
Continue developing and implementing a replacement system that will organize entities by
institution product line, capture relationships between entities, support supervisory workflows,
and document the supervision process.
We will assess our progress through the following eight
performance goals:
Performance goal 1.2.1 / 1.3.1: Perform supervision activities at financial
services institutions under the CFPB’s jurisdiction to foster compliance
with Federal consumer financial laws.
The CFPB’s Supervision Examinations, Supervision Policy, Enforcement, and Fair Lending
Offices collaborate to conduct supervisory activities at bank and nonbank institutions. The
CFPB’s supervisory authority includes banks, thrifts, and credit unions with over $10 billion
in assets, and their affiliates, as well as certain nonbank consumer financial service providers,
such as mortgage lenders, brokers, and servicers; private education lenders; payday lenders; and
larger participants of the consumer reporting and debt collection markets. These supervisory
activities will foster compliance with Federal consumer financial laws, promote a fair consumer
financial marketplace, and prevent unlawful discrimination.
32
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
Performance measure
TABLE 11:
Supervision activities opened during the fiscal year
FY 2012
Actual
FY 2013
FY 2014
FY 2015
149
160
NA
NA
PROGRESS UPDATE AND FUTURE ACTION
In FY 2013, the Bureau continued to implement its supervision program, opening 160
supervisory actions during FY 2013 at large banks and nonbank financial institutions. These
activities included continuing existing supervision programs across product areas including
mortgage origination, mortgage servicing, credit cards, deposits, student lending, and shortterm, small dollar loans. They also included the first ever review of consumer reporting agencies
and nonbank debt collectors.
The CFPB expanded its Supervision and Examination Manual by adding chapters on:
§§ Debt collection examination procedures (October 2012),
§§ Education loan examination procedures (December 2012),
§§ Truth in Lending Act interim procedures (June 2013)
§§ Equal Credit Opportunity Act (ECOA) interim procedures (appraisal and valuation
requirements) (June 2013)
§§ ECOA baseline review procedures (July 2013)
§§ Real Estate Settlement Procedures Act interim procedures (August 2013)
§§ Short-term, small-dollar lending procedures (September 2013)
The Bureau also continued to coordinate with Federal and state regulators to minimize
unnecessary regulatory burden, avoid unnecessary duplication of effort, and decrease the risk of
conflicting supervisory directives. In May 2013, the Bureau entered into a framework with state
financial regulatory authorities that established a dynamic and flexible process for coordination
on supervision and enforcement matters.
Throughout FY 2013, the Bureau also focused on continuing to recruit and hire the staff to
execute the work of the supervision program.
These efforts included hiring of additional
114 examiners across the country and completing the permanent hiring of all four Regional
Directors. The CFPB also made significant investments to build out the Washington, D.C.
33
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. infrastructure, training programs, and systems which contribute to supporting a national
examination force. In FY 2014, the CFPB will continue to grow its diverse and talented team to
accomplish the goals of the supervision program.
Performance goal 1.2.2 / 1.3.2: Effectively initiate supervisory activities
at financial services institutions under the CFPB’s jurisdiction to determine
compliance with the Federal fair lending laws, including the Equal Credit
Opportunity Act (ECOA) and the Home Mortgage Disclosure Act (HMDA).
The CFPB’s fair lending supervision program assesses whether supervised entities have engaged
in, or are engaging in, violations of the Federal fair lending laws. We accomplish this assessment
through examinations that evaluate institutions’ compliance with those laws.
PERFORMANCE MEASURE
TABLE 12:
Fair lending supervision activities opened during the fiscal year 5
FY 2012
Actual
FY 2013
FY 2014
FY 2015
67
47
NA
NA
PROGRESS UPDATE AND FUTURE ACTION
In FY 2013, the Bureau continued its data-driven fair lending supervision operations, opening
10 new Targeted ECOA Exams (focusing on auto and mortgage lending) and 37 new HMDA Data
Integrity Exams.
To increase the transparency of CFPB supervisory processes, the Bureau published the ECOA
Baseline Review Modules, which are used by CFPB examination teams when conducting ECOA
Baseline Reviews. The Bureau also prepared its HMDA Resubmission Schedule and Guidelines,
released in early October 2013 (FY 2014), which provide instruction and additional details on
the HMDA Data Integrity Examination process.
5 The indicator above counts mortgage Targeted ECOA Exams and their associated HMDA Data Integrity Exams
separately as two examinations.
The overall supervision activities indicator combines mortgage Targeted ECOA
Exams and its associated HMDA Data Integrity Exam as a single examination.
34
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. Performance goal 1.2.3 / 1.3.3: Issue examination reports within the
CFPB’s established time periods following the close of examinations.
Effective supervision of financial institutions to foster compliance with Federal consumer
financial laws requires prompt notice to institutions of matters requiring their attention and
action to avoid further violations or consumer harm. A thorough report development and review
process ensures high-quality reports that appropriately explain what the examination team
found and why corrective actions, if any, are required.
PERFORMANCE MEASURE
Percentage of examination reports issued within an established period following the
close of the examination
TABLE 13:
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
Baseline
50%
60%
Actual
NA
15%
NA
NA
PROGRESS UPDATE AND FUTURE ACTION
The CFPB is focused on issuing high-quality examination reports in a timely manner. The
established time period for issuance of reports will be refined as the CFPB continues to examine
more institutions (both bank and nonbank) and our review process is refined. To that end, the
CFPB recently initiated a comprehensive evaluation of the report review process at both the
headquarters and regional levels.
The initial review findings were released to CFPB senior
leadership in December 2013 with implementation of recommendations scheduled to begin in
the second quarter of FY 2014. Even after recommended improvements are implemented, the
CFPB will continue to review and analyze its processes to determine methods for improvement
and increased effectiveness and efficiency.
Performance goal 1.2.4 / 1.3.4: Supervisory matters requiring attention
resolved by the prescribed timeframe.
The CFPB monitors institutions receiving notice of matters requiring attention to ensure that
corrective actions are taken by the prescribed timeframe in response to supervisory activities,
which foster compliance with Federal consumer financial laws and promote a fair consumer
financial marketplace.
35
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. PERFORMANCE MEASURE
The percentage of supervisory matters requiring attention resolved by the prescribed timeframe
in response to supervisory activities.
The percentage of supervisory matters requiring attention resolved by the prescribed
timeframe in response to supervisory activities
TABLE 14:
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
Baseline
80%
80%
Actual
NA
62%
NA
NA
PROGRESS UPDATE AND FUTURE ACTION
The CFPB regions responsible for supervised institutions have given notice to institutions of any
matters requiring attention resulting from supervisory activities and are monitoring responses
by these institutions. The CFPB will conduct on-site reviews of particular issues or actions that
may require independent validation.
The CFPB has and will continue to issue Supervisory Highlights several times per year, through
which it will apprise the public and the financial services industry about its examination
program, including the concerns that it finds during the course of its completed work, and the
remedies that it obtains for consumers who have suffered financial or other harm. The CFPB
believes that Supervisory Highlights will help providers of financial products and services better
understand the CFPB’s supervisory expectations so that they can take action to comply with
Federal consumer financial laws and serve their customers in a fair and transparent way.
The CFPB intends to be transparent about the goals of its supervision program and the steps
being taken to achieve those goals, while protecting the confidentiality of the underlying
financial institution-specific information. In FY 2014, CFPB plans to enhance its ability to
monitor and track the progress of supervisory matters requiring attention by building an
automated tracking capacity into our Supervisory and Examinations System (SES).
Performance goal 1.2.5 / 1.3.5: Cooperate and share information with its
partners in local, state, and Federal law enforcement as part of its efforts
to protect consumers, deter wrongdoers, and build a better marketplace.
This indicator ensures that the CFPB works well with its partners at the local, state, and Federal
level to share information, subject to the Bureau’s regulations and policies on information
sharing, across jurisdictions and to make the best use of limited resources.
36
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
PERFORMANCE MEASURE
Cases in which the CFPB obtains information from local, state, or Federal law
enforcement partners that contributes to CFPB law enforcement actions, or investigations in
which the CFPB cooperates or shares information with law enforcement partners
TABLE 15:
FY 2012
Actual
FY 2013
FY 2014
FY 2015
22
80
NA
NA
PROGRESS UPDATE AND FUTURE ACTION
The Bureau continues to cultivate strong working relationships with its partners at Federal,
state, and local regulators and law enforcement agencies. The Bureau has signed MOUs with the
Conference of State Bank Supervisors and other signatories from all 50 states, plus Puerto Rico
and the District of Columbia, in order to intake the Nationwide Mortgage Licensing System and
the Mortgage Call Report, and to preserve the confidentiality of any information shared between
the parties. In May 2013, the Bureau entered into a framework with state financial regulatory
authorities that established a dynamic and flexible process for coordination on supervision and
enforcement matters. In December 2012, the Bureau signed an MOU with the Department of
Justice to strengthen coordination on fair lending enforcement and avoid duplication of their
respective Federal law enforcement efforts.
The Bureau has also signed approximately 40 other
information-sharing MOUs with Federal, state, and local governmental agencies. For example,
the Office of Enforcement, as well as the Office of Consumer Response, contribute data to the
FTC’s Consumer Sentinel, which is available to local, state, and Federal law enforcement entities
across the country.
The Bureau has shared investigative information with more than 50 different government
agencies since opening its doors and will continue to coordinate and cooperate with its partners
in our efforts to protect consumers. The Bureau is committed to maximizing its ability to protect
and assist consumers through its partners while also ensuring that confidential information
relating to consumers and businesses is appropriately protected.
Performance goal 1.2.6 / 1.3.6: Where the Bureau determines
enforcement action is warranted, file or settle action within two years of
opening its investigation.
Filing enforcement actions in a timely manner is an important measure of the CFPB’s
effectiveness.
The Bureau seeks to balance the need to effectively pursue complex and timeconsuming cases while minimizing any unnecessary delay between conduct and resolution.
Timely pursuit of resolutions increases deterrence and provides consumers with greater
protections of law.
37
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. PERFORMANCE MEASURE
Where the Bureau determines enforcement action is warranted, file or settle action
within two years of opening its investigation
TABLE 16:
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
Baseline
Baseline
TBD
Actual
NA
Baseline under
development
NA
NA
PROGRESS UPDATE AND FUTURE ACTION
Following the determination that enforcement action is warranted, each matter is reviewed at
regular intervals to ensure that it is progressing in a timely manner. Because the CFPB opened
its doors on July 21, 2011, not enough time will have elapsed by September 30, 2014, to form
a complete baseline from which to measure the percentage of enforcement actions that were
filed within two years of the Bureau’s determination that enforcement action was warranted.
Therefore, targets will be established in the future.
In FY 2013, the Office of Enforcement rolled out a series of measures that better enabled
tracking of the timeliness of actions. It also continued to meet hiring goals and to complete
development of policies and infrastructures that enable it to investigate and take action
efficiently and effectively. For example, in FY 2013, the Bureau issued and sought comment
on an interim final rule on the Rules of Practice for Issuance of Temporary Cease-and-Desist
Orders.
The Bureau also issued significant guidance with regard to the following areas related
to enforcement: responsible business conduct and the importance of self-policing, self-reporting,
remediation, and cooperation; unfair, deceptive, or abusive acts or practices in the collection of
consumer debts; indirect auto lending and compliance with the Equal Credit Opportunity Act;
and representations regarding the effect of debt payments on credit scores.
Performance goal 1.2.7 / 1.3.7: Successfully resolve the cases the CFPB
files in court and administrative adjudicative proceedings whether by
litigation, settlement, issuance of a default judgment, or other means.
This measure ensures that the CFPB successfully resolves as many actions as possible while, at
the same time, pursuing complex and challenging actions when appropriate, even when success
is not assured.
38
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. PERFORMANCE MEASURE
The percentage of all cases filed by the CFPB that were successfully resolved through
litigation, a settlement, issuance of a default judgment, or other means
TABLE 17:
FY 1012
FY 2013
FY 2014
FY 2015
Target
NA
75%
75%
75%
Actual
100%
100%
NA
NA
PROGRESS UPDATE AND FUTURE ACTION
In FY 2012, all of the enforcement matters were successfully resolved. In FY 2013, the Office of
Enforcement obtained monetary relief for more than 2.4 million consumers, including redress in
excess of $414 million and civil money penalties totaling more than $50 million. These actions
included an order requiring one of the nation’s largest banks to refund an estimated $309
million to more than 2.1 million customers for illegal credit card practices. This enforcement
action was the result of work started by the Office of the Comptroller of the Currency (OCC),
which the CFPB joined last year.
The Bureau also obtained orders for $6.5 million in restitution
for servicemembers from another major bank and one of its nonbank partner companies. Those
companies were also ordered to stop targeting active-duty military with deceptive marketing
and auto-lending practices.
The Office of Enforcement also secured the Bureau’s first two favorable court decisions in
litigated enforcement actions, resulting in permanent injunctions against two companies and
their operators who were taking advantage of consumers through foreclosure relief schemes,
and orders for the defendants to pay more than $13 million in restitution for their victims. In
addition, the Bureau resolved significant actions against debt relief companies that misled
consumers and charged illegal fees for services they often failed to provide.
Finally, the Bureau obtained more than $15.4 million in penalties from four mortgage insurers
who had been paying unlawful kickbacks to lenders in exchange for business referrals.
In FY
2014 and beyond, the Bureau will seek to continue to successfully resolve cases.
39
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. Performance goal 1.2.8 / 1.3.8: Successfully resolve the fair lending
cases the CFPB files in court and administrative adjudicative proceedings,
whether by litigation, settlement, issuance of a default judgment, or other
means.
When the Dodd-Frank Act created within the CFPB an Office of Fair Lending, it set forth as
one of that Office’s functions the enforcement of Federal fair lending laws, including ECOA and
HMDA. The CFPB seeks to successfully resolve as many fair lending actions as possible while, at
the same time, pursuing complex and challenging actions when appropriate, even when success
is not assured.
PERFORMANCE MEASURE
TABLE 18: The
percentage of all fair lending cases filed by the CFPB that were successfully
resolved through litigation, a settlement, issuance of a default judgment, or other means
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
75%
75%
75%
Actual
100%
NA 6
NA
NA
PROGRESS UPDATE AND FUTURE ACTION 6
In FY 2013, the Bureau worked on two key public enforcement actions announced in early
October 2013 (FY 2014) against Bureau-supervised home mortgage lenders related to HMDA
and Regulation C. The Bureau ordered one bank and one nonbank to pay civil money penalties
($34,000 and $425,000, respectively) for violating HMDA, which requires certain mortgage
lenders to accurately collect and report data about mortgage loan applications. The entities also
were required to correct and resubmit HMDA data and develop and implement an effective
HMDA compliance management system to prevent future violations.
In FY 2014 and beyond,
the Bureau will seek to continue to successfully resolve fair lending cases.
6 Although the stipulations for the two public enforcement actions were executed in September 2013, the denominator for this goal is zero because the consent orders were executed in October 2013, and the result is “N/A”. These two
matters will count as successfully resolved in the FY14 results.
40
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. Goal 2
Empower consumers to live better financial
lives.
The CFPB works to empower consumers with the knowledge, tools, and capabilities they need
in order to make better-informed financial decisions by engaging them in the right moments
of their financial lives, in moments when they are most receptive to seeking out and acting on
assistance. To that end, the CFPB will develop and maintain a variety of tools, programs, and
initiatives that provide targeted, meaningful, and accessible assistance and information to
consumers at the moment they need it, both directly and through others who reach consumers
directly.
TABLE 19:
Budget by program, goal 2
Goal 2
FY 2013
FY 2014
FY 2015
Office of the Director
$1,308,676
$1,128,996
$1,177,931
Operations—
Consumer Response
$39,586,117
$68,782,620
$73,072,513
Consumer Education,
and Engagement
$16,977,742
$23,055,667
$28,716,706
Legal
$721,605
$1,145,348
$1,254,734
External Affairs
$725,095
$1,036,499
$1,171,143
$41,502
$135,867
$147,388
$52,525,490
$28,275,305
$28,121,826
$111,886,226
$123,560,303
$133,662,241
Other Programs
Centralized Services
Total
41
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. FIGURE 3: While almost all Americans are impacted by financial products,7
94%
100%
90%
75%
80%
70%
60%
50%
40%
30%
20%
10%
0%
Report having some form of financial
asset
Report having some form of debt
FIGURE 4: Many face challenges in making financial decisions. 8
19%
of individuals reported that over the past year, their household spent more
than their income.
60%
of individuals lack a rainy day fund to cover expenses even for three
months in case of emergencies.
61%
of individuals said that, when obtaining their most recent credit card, they
did not collect and compare information about cards from more than one
company.
Differences in financial education, capabilities, and skills contribute to this problem. Consumers
represent diverse populations with diverse financial needs, choices, and challenges; they seek
out information about financial choices using a variety of channels. Therefore, the CFPB must
be flexible and adaptable in addressing the highly diverse needs of American consumers.
We
can accomplish this by ensuring that our workforce reflects the faces, ideas, backgrounds and
experiences of the American public.
7 Federal Reserve Board, “Changes in U.S. Family Finances from 2007 to 2010: Evidence from the Survey of Consumer Finances,” Federal Reserve Bulletin, Vol 98, No 2, June 2012, pp. 28, 61, http://www.federalreserve.gov/pubs/
bulletin/2012/pdf/scf12.pdf (Last viewed 8/23/2012).
8 FINRA 2012 Investor Education Foundation’s Financial Capability Study, http://www.usfinancialcapability.org
(Last viewed 1/23/2014).
42
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
FIGURE 5: Percentage of American families obtaining information about borrowing or investing through
various sources 9
Friends, relatives, and associates
Internet
Bankers, brokers, and other sellers of
financial products
Material in the mail
Investing
Calling around
Borrowing
Lawyers, accountants & other financial
advisors
Does not borrow or invest
Magazines, newspaper & other media
0%
10%
20%
30%
40%
50%
The CFPB will accomplish its second goal by
achieving two outcomes
Outcome 2.1: Collect, monitor, respond to and share data associated with
consumer complaints and inquiries regarding consumer financial products
or services.
Outcome leader: Associate Director, Operations
The CFPB provides direct assistance to consumers, in real time, through its Office of Consumer
Response. Consumer Response hears directly from consumers about the challenges they face in
9 Federal Reserve Board, “Changes in U.S. Family Finances from 2007 to 2010: Evidence from the Survey of Consumer Finances,” Federal Reserve Bulletin, Vol 98, No 2, June 2012, pg. 19, http://www.Federalreserve.gov/pubs/
bulletin/2012/pdf/scf12.pdf (Last viewed 8/23/2012).
43
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
the marketplace, brings their concerns to the attention of companies, and assists in addressing
their complaints.
Top consumer complaints
The CFPB’s Office of Consumer Response used a phased approach to the roll-out of complaint
handling by product. In FY 2013, Consumer Response added the ability to handle complaints
about credit reporting, money transfers, and debt collection.
Consumer Response handled approximately 144,000 consumer complaints about credit
cards, mortgages, student loans, bank accounts or services, vehicle and consumer loans, credit
reporting, debt collection, and money transfers in FY 2013.
TABLE 20:
Top consumer complaints in FY 201310
Complaint category
Approximate number of complaints
Mortgage
63,100
Credit card
17,100
Bank accounts and services
18,100
Credit reporting
20,900
Debt collection
13,900
Private student loan
4,100
Consumer loan
4,900
Money transfer
550
Other
1,500
10 Consumer Financial Protection Bureau Consumer Complaint Database.
44
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. TABLE 21:
Top 3 issues for top 5 products in FY 2013
Issue type
Number of complaints
Mortgage
Loan modification, collection, foreclosure
37,700
Loan servicing, payments, escrow account
14,600
Settlement process and costs
2,300
Credit card
Billing disputes
3,100
APR or interest rate
1,200
Identity theft / Fraud / Embezzlement
1,100
Bank accounts and services
Account opening, closing, or management
7,800
Deposits and withdrawals
4,600
Problems caused by my funds being low
2,500
Credit reporting
Credit reporting company's investigation
2,400
Incorrect information on credit report
15,100
Unable to get credit report/credit score
1,900
Debt collection
Continued attempts to collect debt not owed
4,400
Communication tactics
3,000
Taking/threatening an illegal action
1,700
45
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. This outcome will be accomplished through the following
strategies and investments:
Strategies
§§ Collect, analyze, and leverage Consumer Response operational data to enable continuous
improvement of our services to consumers.
§§ Develop a seamless approach to delivery of appropriate and useful Consumer Response
data within the CFPB and to the public so that information is timely, understandable, and
maintains consumer privacy.
§§ Automate key internal operational systems, particularly the intake and routing process, in
order to effectively scale Consumer Response operations.
§§ Maintain a robust training and development program to support Consumer Response
operations as volume and product coverage increase.
Investments
PERSONNEL
Hire additional staff to support intake, investigations, and data analysis in order to review, route,
and address consumer complaints.
CONSUMER RESPONSE SYSTEM AND CONTACT CENTER SUPPORT
Make system investments in order to support the expansion of complaint handling to new
products, improve the ease of use of the consumer and company portals, develop a scalable,
risk-based approach to addressing consumer complaints, and make complaint data available to
stakeholders through additional portals and to the public.
46
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. CONSUMER RESPONSE OPERATIONAL AND PROGRAM SUPPORT
Assist ongoing internal work to execute and refine its operations strategy, focusing on
operational support, performance management support, and performance improvement
services.
OPTIMIZING CFPB COMMUNICATION AND CONSUMER ENGAGEMENT CHANNELS
Assess the use of various communication channels offered by the CFPB and improve the users’
experience according to the consumers’ needs, whether related to submitting a complaint,
accessing CFPB data, or learning about managing important financial decisions.
CONSUMER RESPONSE SYSTEM—NATURAL L ANGUAGE PROCESSING
Gain greater efficiency and effectiveness in complaint handling to respond to the anticipated
increase of interactions with consumers as the Bureau adds to the number of available services
and these services become better known to the public.
We will assess our progress through the following three
performance goals:
Performance goal 2.1.1: Decrease time between receiving and closing a
complaint.
Facilitate efficient handling of a consumer complaint throughout the complaint process – from
when the CFPB receives a complaint through when the CFPB completes an investigation, if
applicable
1. Intake Cycle Time: Ensure complaints are routed to companies for response in a
timely manner
2. Company Cycle Time: Ensure companies provide timely responses to consumer
complaints
3. Consumer Cycle Time: Ensure consumers have adequate time to review company
responses
4. Investigations Cycle Time: Ensure investigations are completed in a timely manner
47
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. PERFORMANCE MEASURE
TABLE 22:
Intake cycle time
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
3 days
3 days
2 days
Actual
7 days
1 day
NA
NA
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
15 days
15 days
15 days
Actual
14 days
12 days
NA
NA
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
30 days
30 days
30 days
Actual
16 days
4 days
NA
NA
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
45 days
45 days
NA
Actual
78 days
78 days
NA
NA
TABLE 23:
Company cycle time
TABLE 24: Consumer
TABLE 25:
cycle time
Investigation cycle time
PROGRESS UPDATE AND FUTURE ACTION
Complaint volume almost doubled from 74,000 complaints in FY 2012 to 144,000 in FY 2013. In
addition, Consumer Response added the ability to accept credit reporting, money transfer, and
debt collection complaints during FY 2013. Consumer Response refined its complaint handling
processes and systems, increasing efficiencies through automation where possible, for example,
to address the increased complaint volume and complexity and to improve its overall complaint
handling operation. Process and system changes implemented in the investigations part of the
complaint lifecycle, as well as product-specific training in FY 2013 are expected to reduce the
Investigations Cycle Time in FY 2014.
48
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
Performance goal 2.1.2: Facilitate the timely response to consumer
complaints by companies.
The CFPB facilitates timely response to consumer complaints by using a dedicated company
portal to route complaints to companies for response. Once routed, complaints appear in real
time in company portals where companies can review and respond to the complaint, triggering
communications to consumers about the company’s response to their complaints.
PERFORMANCE MEASURE
TABLE 26: The
percentage of complaints routed through the company portal
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
85%
87%
89%
Actual
83%
87%
NA
NA
PROGRESS UPDATE AND FUTURE ACTION
In FY 2013, the CFPB introduced a web form for companies to sign up for the company portal
and established portal access and trained staff of approximately 1,600 companies to respond to
complaints on the portal. In FY 2014, the Bureau will continue its work related to the launch of
additional complaint handling by product and service.
Performance goal 2.1.3: Expand capacity to handle consumer complaints.
Consumer complaints shed light on the challenges consumers face in obtaining financial
products and services and inform the CFPB’s efforts to make consumer financial markets work
better and empower consumers to live better financial lives.
PERFORMANCE MEASURE
TABLE 27:
Number of consumer complaints handled
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
125,000
200,000
225,000
Actual
74,000
144,000
NA
NA
PROGRESS UPDATE AND FUTURE ACTION
49
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. In FY 2013, the Bureau expanded the products and services about which it accepts complaints
beyond credit cards, mortgages, bank accounts and services, consumer loans, and private
student loan to include money transfers, credit reporting, and debt collection complaints. In FY
2014, the CFPB began to accept complaints about payday loans and plans to expand to accept
other products and services under its authority.
The Bureau also expanded its Consumer Complaint Database, which started with credit cards
in June 2012, to include complaints about additional products. In March 2013, the Bureau
added complaints about mortgages, bank account and services, private student loans, and other
consumer loan complaints to the database, as well as adding a sub-product field. In May 2013,
the Bureau added credit reporting and money transfer complaints as well as fields for sub-issue
and state.
In November 2013, debt collection complaints were added to the database.
Outcome 2.2: Help consumers understand the costs, risks, and tradeoffs
of financial decisions; build trusted relationships that are interactive
and informative to help consumers take control of their financial choices
to meet their own goals; and raise effectiveness of those who provide
financial education services to increase financial literacy.
Outcome leader: Associate Director, Consumer Education and Engagement
The CFPB works to provide consumers with the information, knowledge, and financial education
needed in order to make well-informed decisions. The Bureau also works to enhance the
financial knowledge and capability of the country as a whole. In addition to improving overall
financial capability, the CFPB focuses on addressing the unique financial challenges faced by
four specific populations.
50
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
Students
29 million Population enrolled in colleges and universities
11
The benefits of higher education are well documented. Four-year college graduates experience a
number of economic benefits over high school graduates, including higher median earnings and
lower unemployment rates. Evidence indicates that these disparities are growing.12 Demand for
higher education and college financing are at all-time highs. Over the past decade, the size of the
student loan market has been increasing steadily.
At over $1.2 trillion in loans outstanding, the
market for student loans is now the second largest component of household debt after mortgages.13
11 U.S. Department of Education, National Center for Education Statistics, Fall 2009 and Fall 2010, table prepared
February 2012, http://nces.ed.gov/programs/digest/d11/tables/dt11_230.asp (Last viewed 8/23/2012).
12 College Board Advocacy and Policy Center, “Education Pays 2010 In Brief: The Benefits of Higher Education for
Individuals and Society,” 2010, http://trends.collegeboard.org/sites/default/files/brief/education-pays-2010-in-brief.
pdf (Last viewed 2/14/2013).
13 The Department of Education and Consumer Financial Protection Bureau, “Private Student Loans Report,” July
20, 2012, http://www.consumerfinance.gov/reports/private-student-loans-report/ (last viewed 9/10/12).
51
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. FIGURE 6: Average cost of attending school is increasing14
$25,000
$23,066
$20,591
$20,000
$19,339
$17,260
$15,000
$10,000
$8,323
Academic year 2006 - 2007
$9,308
Academic year 2011 - 2012
$5,000
$-
2 year institutions 4 year institutions
All institutions
Over half of all students graduate with debt.15
§§ 57% of students who earned bachelor’s degrees in 2011-2012 from the public four-year university at which they began graduated with debt. Average debt per borrower was $22,000.
§§ 65% of students who earned bachelor’s degrees in 2011-2012 from the private nonprofit
four-year colleges at which they began graduated with debt. Average debt per borrower was
$28,000. Total balance of student debt outstanding is large and growing.
Today, outstanding
student debt is over $1 trillion16 having tripled since 2003.17
15 16 17
14 U.S. Department of Education, National Center for Education Statistics, “Digest of Education Statistics 2010,”
table 345, http://nces.ed.gov/pubs2011/2011015.pdf (Last viewed 8/23/2012).
15 College Board Advocacy and Policy Center, “Trends in Student Aid” http://trends.collegeboard.org/student-aid/
figures-tables/average-debt-levels-public-sector-bachelors-degree-recipients-over-time (Last viewed 12/13/2013).
16 The Department of Education and Consumer Financial Protection Bureau, “Private Student Loans Report,” July
20, 2012, http://www.consumerfinance.gov/reports/private-student-loans-report/ (last viewed 9/12/2012).
17 Federal Reserve Bank of New York, “Quarterly Report on Household Debt and Credit,” August 2012, pg. 3, http://
www.newyorkfed.org/research/national_economy/householdcredit/DistrictReport_Q22012.pdf (last viewed
8/30/2012).
52
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
Older Americans
50 million Population age 62 and older
18
Aging poses a number of unique financial challenges. Older Americans face complicated
decisions about finances, retirement, and long-term planning. With the shift from definedbenefit to defined-contribution plans and other forms of “do-it-yourself retirement” such as
IRAs making sound financial choices are especially important. According to the FINRA 2012
Financial Capability study, only 41% of non-retired respondents indicated that they had a
self-directed retirement plan (a 401K or IRA).19 Furthermore, Older Americans are frequently
targeted for scams and financial exploitation.
As people age some will experience a decline in
their ability to handle finances putting them at risk of making poor decisions or increasing the
risk that they will become victims of financial exploitation by scam artists or even by family
members or legal fiduciaries.
As we age, we face a number of complicated decisions related to finances, retirement, and long-term
planning. Aging may impact one’s ability to manage finances.
§§ 22% of Americans ages 71+ have mild cognitive impairment.20
§§ 12% of Americans ages 65+ have Alzheimer’s disease.21
This makes older Americans particularly susceptible to financial mistreatment and exploitation.
§§ 5% of Americans 60+ are victims of financial mistreatment by a family member.22
202122
18 U.S. Census Bureau, “The Older Population in 2010,” table 1, http://www.census.gov/population/age/data/2010.
html (last viewed 2/14/2013).
19 Financial Capability in the United States, FINRA Investment Education Foundation, http://www.usfinancialcapability.org/downloads/NFCS_2012_Report_Natl_Findings.pdf.
20 B.
L. Plassman et al., “Prevalence of Cognitive Impairment without Dementia in the United States,” Archives of
Internal Medicine 148, no. 6: 427–34.
21 Alzheimer’s Association Study, “2011 Alzheimer’s Disease Facts and Figures,” 2011, http://www.alz.org/downloads/facts_figures_2011.pdf (last viewed 8/30/2012).
22 R.
Acierno et al, “Prevalence and Correlates of Emotional, Physical, Sexual and Financial Abuse and Potential
Neglect in the United States: The National Elder Mistreatment Study,” American Journal of Public Health 100 no 2:
292-7.
53
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. Servicemembers
22 million Population (including veterans)
23
The CFPB believes servicemembers should be able to accomplish their mission without worrying
about illegal or harmful financial practices. Military life has challenges with powerful financial
repercussions for uniformed military personnel, veterans, military retirees, and their families. 24
Servicemembers are an attractive target for both good and bad lenders.
§§ Servicemembers are required to pay their legitimate debts and can lose their security clearances over financial problems, so lenders are more confident they can collect their debts.
§§ Military families often start young, leading to big money management decisions by first-time
decision makers.24
§§ Over 39% of enlisted servicemembers are less than 25 years old. 52% of the force is married.
43% have two children.
Servicemembers face unique risks.
§§ Deployments, change of duty stations, and emergencies can lead to unplanned and unique
financial challenges and leave servicemembers without adequate resources to resolve them.
§§ Loyalty to the service leads marketers to tie their pitches to the military, a strategy called “affinity marketing” that can cause servicemembers to overlook unfavorable aspects of the marketed
products.
§§ Frequent relocation can mean household separation and other unforeseen expenses.
23 National Center for Veterans Analysis and Statistics “Veteran Population Projects; FY 2000 to FY 2036;” October
2010, http://www.va.gov/vetdata/docs/QuickFacts/population_quickfacts.pdf (last viewed 8/30/2012).
24 Office of the Deputy Under Secretary of Defense, “2012 Demographics: Profile of the Military Community,”
11/26/2013 2011, http://www.defense.gov/home/features/2011/0111_initiative/ strengthening_our_military_january_2011.pdf (last viewed 8/30/2012).
54
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
Low-income and economically vulnerable
68 million adults are unbanked or underbanked.
46.5 million live below the official poverty line.
25
26
The CFPB focuses on identifying approaches that help this population achieve economic stability
and works to ensure that the financial marketplace works for all consumers, including those who
have been traditionally underserved. 27 28 29
Underbanked: an individual who has a checking or savings account and also used payday lending or
certain other services from nonbanks.
Unbanked: an individual who does not have either a checking or savings account.
Economically vulnerable: low-income households, consumers with thin or no credit file, and
households with limited savings. The CFPB focuses on approaches that enhance the financial
capability of low-income and other economically vulnerable consumers.
Many Americans are or are at risk of becoming economically vulnerable.
§§ 34% of Americans live on income below two times the poverty level (roughly $46,000 for a family of four).27 44% of Americans have almost no savings and would fall into poverty after three
months of job loss or illness that left them without an income.28
Lower income households are more likely to be underserved.
§§~20% of households with income under $30,000 are unbanked.29
25 Federal Deposit Insurance Corporation, “2011 National Survey of Unbanked and Underbanked Households,”
2012, http://economicinclusion.gov/surveys/2011household/.
26 US Census Bureau Income, Poverty, and Health Insurance Coverage in the United States: 2012.
27 U.S. Department of Commerce, “Income, Poverty, and Health Insurance Coverage in the United States: 2011,”
September 2012, pg.
18, table 5, http://www.census.gov/prod/2012pubs/p60-243.pdf (last viewed 2/14/2013).
28 U.S. Department of Commerce, “Income, Poverty, and Health Insurance Coverage in the United States: 2011,”
September 2012, pg. 18, table 5, http://www.census.gov/prod/2012pubs/p60-243.pdf (last viewed 2/14/2013).
29 Corporation for Enterprise Development, “2013 Asset and Opportunity Scorecard,”http://scorecard.assetsandopportunity.org/2013/measure/liquid-asset-poverty-rate (last viewed 8/29/2012).
55
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
This outcome will be accomplished through the following
strategies and investments:
Strategies
§§ Provide tools and information to the public to help individuals make decisions about
money that will serve their own life goals through delivery by both the CFPB and other
trusted intermediaries.
§§ Analyze consumer financial experiences to help shape policy and influence product change
to make the financial environment safer and more beneficial for consumers.
§§ Collaborate with third parties to encourage the development of effective financial skills
and habits by adding in financial capability training to other types of social service
programs.
§§ Strengthening the impact and effectiveness of K-12 and adult financial education by
fostering take-up of best practices; facilitating partnerships; and identifying and seeking to
fill gaps.
Investments
PERSONNEL
Hire additional staff to support financial education, consumer engagement, outreach, policy, and
research activities.
CONSUMER EXPERIENCE PROGRAM
Enable the CFPB to continue to research, design, develop, launch, and continually optimize
the premier consumer-facing products available through consumerfinance.gov, and execute
marketing and editorial strategies to increase awareness of and engagement with these products.
The Consumer Experience Program is a platform for building a trusted relationship with the
American public by offering a series of modules that provide actionable advice to consumers
navigating the most difficult and significant financial decisions they face in the marketplace,
including paying for college, owning a home, and making retirement-related decisions.
CONSUMER EDUCATION CAMPAIGNS
Continue to develop consumer education campaigns on specific topics that may include print
and broadcast media outreach, videos, and low-cost, targeted information to communicate
financial education information to a diverse range of audiences. The topics and approaches of
56
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. the educational campaigns will vary, but may include remittances and the delivery of financial
education through libraries.
UNDERSERVED AND SPECIAL POPUL ATIONS PROGRAM
Pilot projects for improving financial decision making for underserved and special populations,
including youth, low-income Americans, older Americans, and other specific populations.
UNDERSERVED AND SPECIAL POPUL ATIONS OUTREACH
Continue to develop and distribute financial education and empowerment information for
various populations including servicemembers, students, older Americans, low income
Americans, Americans with disabilities, and other specific underserved populations. These
materials are often delivered through intermediaries that provide unique access to consumers
and communities that have unique financial education and empowerment needs.
OPTIMIZING CFPB COMMUNICATION AND CONSUMER ENGAGEMENT CHANNELS
Assess the experience of various communication channels offered by CFPB, especially in support
of improving the consumer’s financial education and ability to manage important financial
decisions.
YOUR MONEY, YOUR GOALS
The agency recently launched the Your Money, Your Goals program, which is used by social
services staff to help clients manage their finances by identifying financial goals, creating
savings plans and managing debt. We are conducting a field test of the financial empowerment
toolkit for social services staff that equips them to “have the money talk” in ways that work
within their service delivery model. Following the field test, the toolkit will be revised and
subsequently launched nationally during 2014.
We will assess our progress through the following three
performance goals:
Performance goal 2.2.1: Significantly increase targeted outreach
activities and digital education materials and research in order to engage
consumers at the right moment.
The CFPB works to arm consumers with the knowledge, tools, and capabilities they need in
order to make better informed financial decisions by engaging them in the right moments
of their financial lives, when the consumer is most receptive to seeking out and acting on
57
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
assistance. To that end, the CFPB offers and is developing a variety of tools, programs, and
initiatives that provide targeted, meaningful, and accessible assistance and information to
consumers around life moments that correspond to major financial choices.
PERFORMANCE MEASURE
TABLE 28: Targeted
populations or organizations directly serving targeted populations reached
by digital content, decision tools, educational materials and resources. 30
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
808,114
2,100,000
2,500,000
Actual
404,057
1,903,417
NA
NA
PROGRESS UPDATE AND FUTURE ACTION
In FY 2013, the CFPB continued to serve consumers with just-in-time financial information
through Ask CFPB, an online database of consumers’ common questions around financial
products and services. The CFPB launched a major release of Paying for College, an online suite
of information and tools for helping consumers understand their after-graduation monthly debt
payments before choosing a financial aid package.
Additionally, the CFPB launched a Spanishlanguage website that includes information on how to submit a complaint in Spanish and Ask
CFPB questions and answers.
In FY 2014, the CFPB will also make improvements to its existing Paying for College product,
alongside marketing investments that will maximize the awareness and value of the product
for consumers. In addition, the CFPB will launch a fully-integrated campaign to educate the
public about changes in the mortgage market, culminating in the launch of Owning a Home,
a consumer experience module. The module will help consumers successfully navigate the
mortgage shopping experience and comparison shop.
In FY 2015, the CFPB will continue improving its existing suite of consumer experience
products, and expand it to cover consumers’ key decisions about retirement.
The CFPB will
present a more seamless, unified experience to consumers across Ask CFPB, Tell Your Story,
and complaint intake. All of this work will be supported by the implementation of an enterprise
30 The actuals and targets above represent unique web visitors only. As the CFPB expands data collection
capabilities on outreach activities, additional content will be included in this measure.
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
marketing strategy that drives awareness and maximizes the reach and impact of the CFPB’s
tools and information.
Performance goal 2.2.2: Improve the understanding of successful
financial decision-making approaches by identifying key success
factors in financial health.
The CFPB believes that financial education’s primary goal is to help consumers take the steps
necessary to make choices that will improve their financial well-being. However, very little
empirical research has been conducted regarding what variables measure financial health in
terms of real-world outcomes for consumers. By defining these variables through data-driven
research, the Bureau will be able to define what knowledge and skills are associated with
financial health. This research will inform the Bureau’s ongoing efforts to identify, highlight, and
spread effective approaches to financial education.
PERFORMANCE MEASURE
Tools created to identify key success factors in financial education.
Targets
FY 2013: Identify variables that are likely to be key drivers of financial health
FY 2014: Develop and test metrics (questions) that accurately measure those variables
FY 2015: Develop and implement framework for integration into Consumer Education and
Engagement programs and activities
Actuals
FY 2012: Contract awarded for research and development project to identify variables and
develop metrics
FY 2013: We identified the variables that are likely to be key drivers of financial health.
PROGRESS UPDATE AND FUTURE ACTION
The Bureau’s work towards the performance goal is on track, with expected deliverables and
interim targets being met according to the anticipated project timeline.
In FY 2013, the Bureau conducted a broad array of research to identify what specific knowledge,
behavior, and personal traits are likely to predict financial well-being for American consumers.
This included a thorough formal review of the most relevant research literature; designing,
completing and analyzing extended one-on-one interviews with a socioeconomically and
geographically broad sample of working-age and older Americans and professional financial
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
practitioners; and soliciting and collecting collaborative input and peer discussion from
academic, policy, and practicing experts. Based on this, the CFPB has developed a preliminary,
first-of-its-kind, comprehensive definition of financial well-being that speaks to the goals and
perspectives of consumers, as well as a set of specific variables that are likely to be key drivers of
financial well-being.
In FY 2014, the CFPB will rigorously develop and test metrics (measurement tools) that
accurately measure financial well-being and related variables. These measurement tools
will allow the CFPB and others to more accurately assess consumer financial health, target
educational efforts, test hypotheses about key drivers of financial health, and assess the
effectiveness of different approaches to improving consumer financial well-being. The CFPB will
then promote the most effective approaches that support better outcomes for consumers.
Once the research is complete, the CFPB’s Division of Consumer Education and Engagement will
develop and implement a framework to integrate this project’s findings and new measurement
tools into other consumer education and engagement initiatives.
This will likely include our
research projects, direct-to-consumer resources, and recommendations for intermediaries
to promote effective approaches to the financial education field. This effort is detailed under
“Underserved and Special Populations Research” in the Investments section of Outcome 3.2.
Performance goal 2.2.3: Promote fair lending compliance and education
by leading and participating in fair lending outreach activities.
As one of its core functions, the Office of Fair Lending is responsible for “working with
private industry, fair lending, civil rights, [and] consumer and community advocates on the
promotion of fair lending compliance and education.” (Dodd-Frank Act, Section 1013(c)(2)(c).)
CFPB conducts fair lending outreach activities through numerous channels, such as issuing
compliance bulletins targeted to industry; delivering speeches and presentations on fair lending
and access to credit matters to industry, consumer and community groups, and others; and
participating in smaller meetings and discussions with external stakeholders.
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. PERFORMANCE MEASURE
TABLE 29:
Number of outreach activities on fair lending and access to credit
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
55
35
35
Actual
51
56
NA
NA
PERFORMANCE GOAL UPDATE AND FUTURE ACTION
In FY 2013, the Office of Fair Lending and Equal Opportunity executed against its mission to
promote fair, equitable, and nondiscriminatory access to credit for individuals and communities
by participating in 56 fair lending outreach activities.
Through numerous speeches, panel remarks, presentations, and smaller discussions on
fair lending matters, the Bureau reached out to various important stakeholders, including
congressional committee staff, industry leaders and participants, national and state fair lending
and fair housing groups, community advocates, and consumer advocates. These engagements
allowed the Bureau both to explain existing and emerging fair lending issues and risks to
external stakeholders and to inform the Bureau’s fair lending oversight work.
The Bureau issued a bulletin on compliance in indirect auto lending (CFPB Bulletin 2013-02)
and prepared for release a bulletin on HMDA compliance management and resubmission
(CFPB Bulletin 2013-11) to help increase transparency around our supervisory process in both
mortgage and auto lending and to provide guidance to industry actors on effective fair lending
compliance.
Going forward, the Bureau will continue to champion fair and equal access to credit through
outreach activities, and plans on pursuing an even more concentrated approach. The Bureau will
be conducting fewer and more strategically focused activities on fair lending, and has adjusted
the targets for FY 2014 and FY 2015 to reflect this strategic approach in fair lending outreach.
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. Goal 3
Inform the public, policy makers, and the
CFPB’s own policymaking with data-driven
analysis of consumer finance markets and
consumer behavior.
Understanding how consumer financial markets work, the avenues for innovation in financial
products and services, and the potential for risk to consumers is a core component of the
CFPB’s mission. The CFPB’s aim is to ground all of its work—from writing rules and litigating
enforcement actions to its outreach and financial literacy efforts—in the realities of the
marketplace and the complexities of consumer behavior.
This requires use of data, strong partnerships within the CFPB and externally to ensure that
we continue to monitor markets effectively, technology tools, and employees with the skills and
capabilities needed to analyze data and distill insights.
The CFPB’s research will support building an understanding of the markets we regulate and
the nature of consumer behavior in these markets. It will also support the consideration of the
potential benefits and costs of the CFPB’s work to consumers and institutions, including effects
on access by consumers to consumer financial products or services.
In all of the data used for its analyses, the Bureau will work to ensure that strong protections
are in place around personally identifiable information. The Bureau will generally obtain
datasets in a format such that no information is directly identifiable, and research/analysis
products resulting from such data will use similarly de-identified information.
The Bureau treats
the information collected from participating persons and institutions consistently with our
confidentiality regulations and all data and analyses are subject to legal and privacy review prior
to their release.
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. TABLE 30: Budget
by program, goal 3
Goal 3
FY 2013
FY 2014
FY 2015
Office of the Director
$1,308,676
$1,128,996
$1,177,931
Consumer Education,
and Engagement
$5,285,542
$8,533,404
$9,871,720
$23,712,486
$31,987,401
$28,810,208
$1,030,864
$1,511,124
$1,689,424
External Affairs
$725,095
$1,036,499
$1,171,143
Other Programs
$174,092
$431,463
$479,673
Centralized Services
$26,284,459
$13,808,109
$12,822,081
Total
$58,521,214
$58,436,996
$56,022,179
Research, Markets,
and Regulation
Legal
The CFPB will accomplish its third goal by
achieving two outcomes
Outcome 3.1: Monitor markets and conduct research to surface financial
trends and emergent risks relevant to consumers.
Outcome leader: Associate Director, Research, Markets and Regulations
This outcome will be accomplished through the following
strategies and investments:
Strategies
§§ Acquire, collect, and maintain the data necessary to properly monitor select markets for
emerging risks and positive innovations.
§§ Coordinate with other Federal agencies, including the Office of Financial Research, to
ensure the most efficient use of data and avoid duplication.
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. §§ Build and maintain technological infrastructure required to support market intelligence
through the integration of diverse internal and external data.
Investments
PERSONNEL
Hire additional experts in particular industries, as well as additional economists and other
researchers.
CREDIT CARD DATABASE
Maintain a credit card database, including both summary and de-identified loan-level data,
covering approximately 80% of the credit card marketplace. This investment will allow the
Bureau to conduct empirically sound research essential to informing data-driven decisions
throughout Bureau activities.
MORTGAGE DATABASE
Develop and maintain databases that will provide the Bureau with a representative view of the
mortgage market, demonstrating up to 95% of the market.
EVIDENCE-BASED CONSUMER FINANCIAL MARKET RESEARCH
Conduct evidence-based research to build foundational knowledge in financial trends and
emergent risks relevant to consumers.
OTHER MARKET DATA
Acquire and maintain various commercially available market datasets in order to support
research and regulations activities.
HMDA DEVELOPMENT AND IMPLEMENTATION
Support a concept-of-operations study and development of future-state functional requirements
in consideration of a potential redesign of the current HMDA framework.
We will access our progress through the following performance
goal:
Performance goal 3.1.1: Monitor the credit card and mortgage markets
through data.
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. The credit card and mortgage markets are both critical to consumers. Having quantitative data
on both markets makes it easier for the Bureau to monitor trends and implications for both
consumers and providers. These data also strengthen the evidentiary basis for Bureau policymaking.
PERFORMANCE MEASURE
TABLE 31:
Percentage of the credit card market monitored through data
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
80%
80%
80%
Actual
77%
85%
NA
NA
TABLE 32:
Percentage of the mortgage origination and servicing markets monitored through data
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
95%
95%
95%
Actual
95%
90%
NA
NA
PROGRESS UPDATE AND FUTURE ACTION
The reported Actual FY 2013 level of performance for data coverage of the mortgage market
is 90%, which is lower than the reported FY 2012 coverage of 95%. In FY 2012, the CFPB was
able to combine data from HMDA with the data from Nationwide Mortgage Licensing System &
Registry (NMLS) (and some other sources) to create an aggregate picture of 95% of the market.
This match has not yet been completed in FY 2013, and as a result, the Bureau reports the 90%
figure for FY 2013 based primarily on the HMDA data.
Importantly, the CFPB has the NMLS
data and other data as well: however, without doing the necessary matches and analysis, we
chose to report the HMDA-based estimate alone. Going forward, the Bureau plans to apply a
standard method for assessing data coverage of the mortgage market.
Through the maintenance of the CFPB Credit Card Database, the Bureau is able to cover a
sizable portion of the cards market with de-identified loan-level detail. The Bureau uses publicly
available resources (HMDA, NMLS, call reports) for monitoring the mortgage markets, and
supplements these sources with two commercial services for data regarding originations and
servicing.
CoreLogic provides servicing data on loans serviced by the largest servicers in the US
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. (just over 53% of outstanding mortgages) and BlackBox LLC provides data on loans extant in
private label securities.
In FY 2013, the CFPB began a partnership with the Federal Housing Finance Agency (FHFA)
to build the National Mortgage Database (NMDB). This work continues in FY 2014. For this
database, the FHFA and the Bureau have procured (from a credit reporting agency) credit
information with respect to a random and representative sample of 5% of mortgages held by
consumers. The NMDB is the first dataset that will provide a truly representative sample of
mortgages so as to allow analysis of mortgages over the life of the loans, including firsts, seconds,
and home equity loans.
In all of the data used for its analyses, the Bureau will work to ensure that strong protections
are in place around personally identifiable information.
The Bureau will generally obtain
datasets in a format such that no information is directly identifiable and research/analysis
products resulting from such data will use similarly de-identified information. The Bureau treats
the information collected from participating persons and institutions consistently with our
confidentiality regulations and all data and analyses are subject to legal and privacy review.
Outcome 3.2: Articulate a research-driven, evidence-based perspective on
consumer financial markets, consumer behavior, and regulations to inform
the public discourse, inform Bureau thinking on priority areas, identify
areas where Bureau intervention may improve market outcomes, and
support efforts to reduce outdated, unnecessary, or unduly burdensome
regulations.
Outcome leader: Associate Director, Research, Markets, and Regulations
This outcome will be accomplished through the following
strategies and investments:
Strategies
§§ Collect and analyze data in order to improve understanding, regulation, and functioning of
consumer financial markets and behavior.
§§ Help to make the market work better for special populations such as students, older
Americans, servicemembers and veterans, and low-income and economically vulnerable
consumers through selected policy work.
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. §§ Institutionalize cross-Bureau collaboration to ensure our work is informed by the CFPB’s
internal research and expertise.
§§ Develop and maintain the tools and technology required to effectively, efficiently, and
securely disseminate data and research for internal and external audiences.
Investments
PERSONNEL
Expand research capacity in order to achieve Bureau-wide priorities.
COMPLIANCE COST STUDY
Study the costs of compliance related to existing and new consumer regulations to improve the
Bureau’s capacity to write effective rules and ease compliance burden.
FINANCIAL EDUCATION RESEARCH
Develop and test metrics that effectively measure relevant consumer financial knowledge,
behavior, and well-being. The results of these studies will help the CFPB, other Financial
Literacy and Education Commission agencies, and the broader financial education field to
develop and support policies and programs that lead to better financial outcomes, skills, and
habits for American consumers.
UNDERSERVED AND SPECIAL POPUL ATIONS RESEARCH
Identify unique factors that influence financial capabilities for youth, low-income Americans,
older Americans, and other underserved populations, as well as evidence-based practices
for effective financial education and empowerment. Related pilot programs will advance the
understanding of interventions that can optimize financial decision-making.
CONSUMER EXPERIENCE PROGRAM
Enable the CFPB to research and continue optimizing the effectiveness of the Consumer
Experience Program, a series of digital media modules that proved actionable advice to
consumers navigating the most difficult financial decisions they face in the marketplace.
FINANCIAL EDUCATION INNOVATIONS
Design, develop, and arrange for testing of strategies to improve consumer financial decision-making.
67
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. EVIDENCE-BASED CONSUMER FINANCIAL MARKET RESEARCH
Conduct evidence-based research to inform policy-making and build foundational knowledge
about how consumers make financial decisions
KNOW BEFORE YOU OWE—MORTGAGE CLOSING
Establish a dialogue and pilot tests regarding the stack of documentation associated with closing
and potential innovations in the market that might create a more educational and empowering
process for consumers.
FINANCIAL EDUCATION METRICS
Conduct research to determine how to measure financial well-being and identify the knowledge,
skills, and habits associated with financially capable consumers. The Bureau will develop and
test metrics that effectively measure relevant consumer financial knowledge, behavior, and
well-being. The results of this study will help the CFPB, other Financial Literacy and Education
Commission agencies, and the broader financial education field to develop and support policies
and programs that lead to better financial outcomes, skills, and habits for American consumers.
This is a continuation of the financial education metrics project which began in FY 2013. In
FY 2014, the financial education metrics project will extend its findings from adult financial
well-being research (metrics project) to children and youth and advance the findings from the
quantitative testing of the financial well-being metrics developed for working adults.
We will access our progress through the following performance
goal:
Performance goal 3.2.1: Increase the number of reports produced about
specific consumer financial products, markets, or regulations and on
consumer decision-making.
The Bureau conducts qualitative and quantitative research to deepen understanding of
consumer decision making; consumer financial products and markets; and the effects of
consumer financial regulations and policies.
Periodically, the Bureau publishes reports of its
research.
Bureau and independent research are intended to provide the Bureau and other policy makers
with a stronger evidentiary foundation for policymaking. They are also intended to inform the
public and enhance the public’s participation in policymaking.
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. PERFORMANCE MEASURE
Reports produced about specific consumer financial products, markets, or regulations
and on consumer decision-making
TABLE 33:
FY 2012
FY 2013
FY 2014
FY 2015
Target
4
5
5
5
Actual
2
4
NA
NA
PROGRESS UPDATE AND FUTURE ACTION
Preparing reports is central to the Bureau’s commitment to evidence-based policy-making. The
Bureau issued four prominent reports in FY 2013. These reports are intended to deepen the
public’s understanding of these issues and provide the Bureau and other policy makers with a
stronger factual foundation on which to make policy judgments. The Bureau’s Research, Markets
and Regulations Division released the following notable public reports in FY 2013:
§§ Analysis of Differences between Consumer- and Creditor-Purchased Credit Scores
§§ Key Dimensions and Processes in the U.S.
Credit Reporting System: A review of how the
nation’s largest credit bureaus manage consumer data
§§ Payday Loans and Deposit Advance Products: A White Paper of Initial Data Findings
§§ CFPB Study of Overdraft Programs: A white paper of initial data findings
In addition to these four reports released by the Bureau’s Research, Markets and Regulations
Division, the Bureau’s Consumer Engagement and Education division released the following
notable public reports in FY 2013:
§§ Senior Designations for Financial Advisors: Reducing Consumer Confusion and Risks
§§ Navigating the Market: A comparison of spending on financial education and financial
marketing
In the future, the Bureau will include Consumer Engagement and Education’s reports in the
actuals and targets for this Performance measure. The Bureau has information gathering and
other data analysis underway that will yield public reports in FY 2014. These research areas
include: a study of the CARD Act; a study of compliance costs as related to the Bureau’s depositrelated regulations; a review and examination of pre-dispute arbitration clauses and their effects
69
CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
on consumers; and other planned topics. With two of the above reports already released by
November 2013, we are on schedule to meet the FY 2014 goal of publishing at least five reports.
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. Goal 4
Advance the CFPB’s performance by
maximizing resource productivity and
enhancing impact.
In order to maximize the effectiveness of the consumer protections established by Federal
consumer financial law, the CFPB must acquire, maintain, support, and direct its resources in
a way that enables it to operate efficiently, effectively, and transparently. This means developing,
maintaining, and continuously improving the policies and controls in place to ensure the CFPB
has the resources it needs and puts those resources to the best use possible.
A key mission of the CFPB is to make financial products and services more transparent in
the consumer marketplace. The CFPB will strive to achieve the same level of commitment to
transparency in its own activities, while respecting consumer privacy and confidentiality. To
accomplish this, the CFPB will develop and implement mechanisms and provide channels to
maintain an open, collaborative dialogue with the public.
TABLE 34:
Budget by program, goal 4
Goal 4
FY 2013
FY 2014
FY 2015
$1,308,676
$1,128,996
$1,177,931
$54,171,404
$68,684,285
$69,744,184
Legal
$4,845,062
$6,761,617
$7,171,196
External Affairs
$2,658,680
$3,800,496
$4,294,192
$412,830
$992,961
$1,003,803
$73,499,876
$40,162,723
$35,124,640
$136,896,529
$121,531,078
$118,515,946
Office of the Director
Operations
Other Programs
Centralized Services
Total
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
Outcome 4.1: Attract, engage, and deploy a diverse workforce that meets
dynamic challenges and provides effective oversight of the consumer
financial marketplace.
Outcome leader: Associate Director, Operations
The CFPB continues to pursue a strategic imperative to recruit and hire highly qualified
individuals, focusing on filling vacancies at its headquarters in Washington, DC, and in its
examiner workforce distributed across the country. To do so, the CFPB continued to identify
and adopt best practices from the private and public sectors to hire, train and develop a diverse
world-class workforce with the knowledge, skills and abilities required to effectively achieve our
mission.
As we continue to work towards full capacity over the next couple of years, we are also placing an
increased emphasis on the development and retention of those highly qualified individuals now
on staff. This expanded focus will allow improvement efforts targeting the employee experience,
development, retention and engagement.
This outcome will be accomplished by the following strategies
and investments:
Strategies
§§ Recruit and retain a high-quality, diverse staff through effective workforce planning and
talent acquisition methods, strong engagement, a comprehensive diversity and inclusion
program, and a competitive compensation and benefits package.
§§ Create and sustain a high-performing workforce through innovative workforce learning,
development and performance-management programs.
§§ Develop human capital infrastructure by creating human capital policies, improving
human capital information systems, effectively allocating and prioritizing resources, and
using mutual accountabilities to achieve desired human capital outcomes.
Investments
PERSONNEL
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. Continue to build capacity across the Bureau by hiring high-performing, diverse employees.
HUMAN CAPITAL SHARED-SERVICES, INFRASTRUCTURE, AND OPERATIONS
Contract with the Department of the Treasury to provide a variety of services, including pay and
leave administration support, employee benefits administration and support, and human capital
help desk and reporting support for timekeeping, personnel documentation, and performance
management systems.
LEARNING, LEADERSHIP, AND ORGANIZATION DEVELOPMENT FACILITATION AND DESIGN
Support the development of high-quality learning solutions including core competency training,
consumer financial market overview, new supervisor training, leadership training, diversity and
inclusion training, and manager skill-building through coaching and organization development
services. Support the improvement of organizational and group effectiveness through
organizational interventions, workforce planning, and group or team action planning support.
OUTREACH, CANDIDATE RECRUITING, AND CANDIDATE SELECTION SUPPORT
Invest in candidate outreach, sourcing, recruiting, and selection support services to reach,
attract, and hire high-performing, diverse staff. Invest in services such as print and social
media, strategic, tailored candidate assessment methods to improve decision-making. Build
and maintain strategic partnerships with colleges, universities, professional organizations, and
affinity groups that serve diverse populations.
We will assess our progress through the following two
performance goals:
Performance Goal 4.1.1: Recruit and retain high-performing, diverse
employees with the right skills and abilities to meet mission driven goals
and objectives.
A wide array of skills and abilities, which represent diversity and organizational makeup, is
required for success in achieving our mission.
We assess progress and performance on this
goal by measuring employee perceptions of 1) the technical competence of the workforce
and 2) diversity and inclusiveness. Strategies to improve in these areas target organizational
effectiveness, workforce planning, diversity and inclusiveness interventions at the group and
organizational levels.
PERFORMANCE MEASURE
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. TABLE 35: Annual
Employee Survey (AES) rating on perceptions of technical competence of the
CFPB staff (% favorable) 31
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
68.5%
68.5%
68.5%
Actual
65%
67%
NA
NA
PERFORMANCE MEASURE
TABLE 36: Annual
Employee Survey rating on perceptions of workplace diversity and inclusiveness
of the CFPB staff (% favorable) 32
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
76%
76%
76%
Actual
74.8%
76%
NA
NA
PROGRESS UPDATE AND FUTURE ACTION
In FY 2013, the Bureau recruited and hired talented employees, growing from 970 employees
at the beginning of FY 2013 to 1,355 at fiscal year’s end. The Offices of Human Capital, Minority
and Women Inclusion (OMWI), and Equal Employment Opportunity (EEO) collaborated to
develop targeted recruiting strategies and enhance workplace diversity. Strategies applied
in FY 2013 that significantly expanded FY 2012 activity, include: partnering with affiliate
organizations33 to reach qualified diverse professionals; recruiting at nearly 30 minority-focused
career events, and using internships to reinforce our diverse talent pipeline. As of the end of
FY 2013, there were 24 interns on staff, 15 recent graduates, and 15 Presidential Management
Fellows, including those employees continuing on Pathways appointments after conversion from
other student programs.
The Bureau also expanded the use of enhanced candidate assessment
tools to support hiring into more than 70 different jobs at all levels of the organization and
31 The technical competence composite is comprised of ratings on three items from the AES survey, including “the
workforce has the job-relevant knowledge and skills necessary to accomplish organizational goals.”
32 The workplace diversity and inclusiveness composite is comprised of ratings on two items from the AES survey,
which are “managers/supervisors/team leaders work well with employees of different backgrounds.” and “my supervisor supports my need to balance work and other life issues.”
33 Affiliate organizations included: the National Black MBA Association, the League of United Latin American Citizens, and Association of Latino Professionals in Finance and Accounting.
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. enhanced the technical training and on the job learning supporting employees in a variety of
positions. These efforts contributed to a notable improvement in employee satisfaction with
training received for current positions. In the future, the CFPB will continue its efforts to recruit
and retain highly qualified and diverse candidates for a vibrant workforce.
In the area of technical competence, the CFPB has demonstrated improvement from FY 2012
level. In FY 2014, the Office of Human Capital will continue to refine the set of items utilized to
assess technical competence.
In addition, interventions to define learning and development, core
competencies, and career paths should have a positive impact on this metric.
Performance goal 4.1.2: Increase the level of employee engagement.
Engagement has been described as a state of passion and commitment to the organization’s
goals on the part of each employee, which leads to their willingness to invest discretionary effort
to ensure success. In the case of the Bureau, maintaining the initial motivation and excitement
of the new workforce is critical to our future success. Individual employees’ perception of the
level of employee engagement is one way to measure the Bureau’s success engaging its employees.
PERFORMANCE MEASURE
TABLE 37: Annual
Employee Survey Engagement composite rating (% favorable) 34
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
76.5%
76.5%
76.5%
Actual
74%
73%
NA
NA
PROGRESS UPDATE AND FUTURE ACTION
The CFPB continues to present employees with a wide range of opportunities to demonstrate
personal commitment to the organization’s mission and goals.
Concurrently, the CFPB has
further developed functions dedicated to monitoring and improving organizational performance
metrics, including metrics related to workplace environment and employee engagement. The
CFPB’s Culture Team was reinvigorated under new leadership and the Bureau has started to
34 The employee engagement composite is comprised of ratings on nine items from the AES survey, such as “my
work gives me a feeling of personal accomplishment” and “the work I do is important.”
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. forge a strong partnership with the CFPB’s recently elected chapter of the National Treasury
Employees Union (NTEU).
The CFPB also initiated efforts to improve employee engagement within offices and Divisions.
However, many of these efforts started in the second half of FY 2013, leaving insufficient time
before the July AES for improvements to take hold. The CFPB anticipates more positive results
in FY 2014 due to concerted action planning efforts.
In FY 2014, the CFPB continues to ensure that reporting of AES 2013 results at the Division and
office levels takes place in a structured and consistent manner, further improving on successes
achieved in FY 2012. The Bureau’s Office of Human Capital works directly with leaders of all
Divisions to initiate action planning based on AES 2013 findings. Division leaders will bear
responsibility for delivering improvement efforts and reporting on progress.
Outcome 4.2: Enable the innovative use of technology for the benefit of
efficient internal processes and effective public engagement.
Outcome leader: Associate Director, Operations
The CFPB is committed to staying on the leading edge of technology and leveraging its
technological resources to provide significant business value with lower costs.
From developing
online products that help inform consumers to making critical data available internally and to
the public, technology is and will continue to be core to the CFPB’s accomplishing its mission.
This outcome will be accomplished through the following
strategies and investments
Strategies
§§ Establish a secure, responsive and cost-effective technology infrastructure to enable a 21st
century agency.
§§ Continue to build, develop and improve next-generation online tools that help consumers
get answers to questions. make financial decisions, and confront difficult financial
circumstances.
§§ Maintain a robust platform for the public to visualize and make use of data maintained by
the Bureau, such as consumer complaint data.
§§ Create a suite of enterprise-wide technology capabilities that maximizes the efficiencies of
resources and costs.
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. Investments
PERSONNEL
Hire additional staff to enable the organization’s continued support of Bureau activities
including managing, operating and safeguarding the IT systems that host and store the CFPB’s
data; designing, and developing tools to facilitate data-driven analysis and consumer education;
and implementing a 21st century cloud-based infrastructure that serves as the foundation for
innovative technology.
INFRASTRUCTURE
Facilitate the CFPB’s infrastructure independence efforts by allowing for the migration of critical
services to a flexible, scalable CFPB-managed infrastructure capable of sustaining the Bureau’s
future growth.
DESIGN AND SOFTWARE DEVELOPMENT SUPPORT
Continue to strengthen the Bureau’s capacity to design, develop, implement and maintain
new tools with enhanced capabilities, features and functionalities for a variety of business
applications that support the Bureau’s mission.
CYBERSECURIT Y
Continue to enhance a robust cybersecurity program that secures and safeguards
communications, data, and IT resources through a combination of comprehensive policies,
continuous monitoring, and leading technologies.
PORTFOLIO MANAGEMENT
Enhance the successful deployment of projects through the continued use of disciplined
methodologies including project management and agile development and facilitate the
development of the long-term technology strategy that guides future mission capabilities.
DATA INFRASTRUCTURE AND ANALYSIS
Continue to build and develop a data driven strategy that is deployed on a technology
architecture with scalable capabilities that will allow the Bureau to use and manage data to
conduct predictive analytics and aid in better decision making.
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. We will assess our progress through the following two
performance goals:
Performance goal 4.2.1: Release new datasets to the public, where
legally permissible and appropriate, to allow for innovative uses of the
data by individuals, non-profit entities, and businesses for the benefit of
consumers.
The public uses data released by the government to build tools and provide resources to
consumers to help them make the best financial decisions. The CFPB wants to support a culture
of information and transparency by releasing useful data to the public when doing so is legally
permissible and appropriate.
PERFORMANCE MEASURE
TABLE 38:
Provision of data to the public in legally permissible and appropriate instances 35
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
5
7
7
Actual
3
4
NA
NA
PROGRESS UPDATE AND FUTURE ACTION
In FY 2013, the CFPB released four datasets including the Consumer Complaint Database, the
Credit Card Agreement Database, the College Credit Card agreements and the Survey of Credit
Card Pricing Plans. Additionally, in September 2013, the CFPB provided access to the HMDA
data via its website.
In January 2014, the CFPB will launch its public data platform where the HMDA data will
be available for use by industry advocates and consumers to intuitively search and work
with the data and conduct analysis. The CFPB plans to release two more large datasets in FY
2014.
When releasing datasets, the Bureau protects certain data in the database from public
disclosure, including personally-identifiable information, in accordance with applicable laws and
regulations.
Performance goal 4.2.2: Improve the efficiency of internal processes and
35 Datasets are reported on a cumulative basis.
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. procedures.
Technology can help us improve the efficiency of the CFPB so that we serve more consumers in a
better way.
PERFORMANCE MEASURE
Efficiency of internal processes and procedures
Targets
FY 2013:
1. Deploy a business intelligence tool
2. Deploy a business process automation platform and develop applications leveraging it
FY 2014:
1. Continue to build out core infrastructure services
FY 2015:
1. Operate and maintain core infrastructure services
2. Deploy mission capabilities to support Supervision and Enforcement activities
Actuals
FY 2012:
1. Launched AskCFPB
2. Launched an upgrade of the Intranet including an upgraded wiki, personnel directory,
and internal news feed
3. Deployed a performance management system
FY 2013:
1. Development of Business Intelligence Tool
2. Debt Collection Product Launch
3. Paying for College
4. Infrastructure Independence Phase I
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. PROGRESS UPDATE AND FUTURE ACTION
In FY 2013, the Bureau developed a business intelligence tool that provides a user-friendly
platform for exploring and analyzing data. This platform will be implemented by the first
quarter within FY 2014. During FY 2013, the Bureau initiated an effort to prioritize and manage
the Bureau’s information technology needs resulting in more streamlined and disciplined
processes. The results of the prioritization efforts allowed for the successful deployment of
over 50% of technology projects, including the Debt Collection and Paying for College product
launches.
In FY 2014, the Bureau will continue the work to build out the core infrastructure capabilities
and create a long term technology strategy that guides future mission capabilities.
Outcome 4.3: Enable the operation of a high-performing organization by
ensuring effective and efficient management, protection of CFPB resources,
rigorous internal controls, and full compliance with the law.
Outcome leader: Associate Director, Operations
The CFPB has the obligation to act as a good steward of public funds.
The CFPB will monitor its
operations and conduct periodic evaluations to ensure it maintains good financial practices and
robust internal controls.
This outcome will be accomplished through the following
strategies and investments:
Strategies
§§ Use data to supervise and coordinate all financial operations of the Bureau consistent with
the requirements of laws and regulations.
§§ Develop a team of high-performing professionals with expertise in budget, financial
management, procurement, internal controls and travel operations.
§§ Develop and maintain integrated accounting and financial management and travel systems
in order to support the effective use of resources.
Investments
PERSONNEL
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. Hire additional staff to ensure resources continue to be used efficiently and effectively, and
transparency and accountability are maintained.
AUDITS OF THE BUREAU
Continue to work with the Office of Inspector General (OIG) of the Board of Governors of the
Federal Reserve System and the Bureau of Consumer Financial Protection, the Government
Accountability Office (GAO), and an independent contractor for external auditing and oversight
of the Bureau’s operations and budget.
FINANCIAL MANAGEMENT SUPPORT SERVICES
Continue to provide financial management services in the areas of budget execution, purchasing,
accounts payable, accounts receivable, and general ledger and fixed assets.
INTERNAL CONTROLS
Continue to invest in resources that maintain effective internal controls, and follow appropriate
models for internal controls, such as the Federal Managers’ Financial Integrity Act of 1982
(FMFIA), and the objectives on financial reporting as established under Dodd-Frank and best
practices derived from OMB Circular A-123.
We will assess our progress through the following three
performance goals:
Performance goal 4.3.1: Obtain an unmodified “clean” audit opinion on
the CFPB’s financial statements.36
An unmodified opinion from GAO of the CFPB’s internal operations confirms that the Bureau
maintains sound financial practices and robust internal controls.
PERFORMANCE MEASURE
Unmodified “clean” audit opinion on financial statements
36 The American Institute of Certified Public Accountant’s Auditing Standards Board updated sections of the
Statements of Auditing Standards with respect to the definition of the types of audit reports issue. Based on these
changes, reports on audited financial statements will use the term ‘unmodified opinion’ instead of ‘unqualified
opinion’ beginning in fiscal year 2013.
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. Targets
Target for FY 2013: Unmodified audit opinion
Target for FY 2014: Unmodified audit opinion
Target for FY 2015: Unmodified audit opinion
Actuals
Actual result for FY 2012: Unqualified audit opinion
Actual result for FY 2013: Unmodified audit opinion
PROGRESS UPDATE AND FUTURE ACTION
The CFPB has received an unmodified opinion from the GAO on its FY 2013 financial statements.
GAO also previously provided unqualified opinions on the Bureau’s FY 2012 and 2011 financial
statements. These opinions confirm that the CFPB has implemented effective internal control
over the efficiency of operations, compliance with laws and regulation, and financial reporting.
The CFPB will continue to maintain a robust internal control framework over operations and
financial reporting.
Performance goal 4.3.2: Award 90% of contracts competitively.
Competing procurement actions allow for competitive market pricing, stronger proposal
submissions, and a distributed vendor base in support of the Bureau. Public value is also derived
as money is being spent effectively.
PERFORMANCE MEASURE
TABLE 39:
Percentage of contracts competitively awarded
FY 2012
FY 2013
FY 2014
FY 2015
Target
NA
90%
90%
90%
Actual
93%
83%
NA
NA
PROGRESS UPDATE AND FUTURE ACTION
The CFPB is currently tracking competition and reporting data measurements within the agency
on a quarterly basis.
At 90% the CFPB’s competition goals for FY 2013 through FY 2015 are ambitious but realistic
and designed to position the Bureau as a leader-by-example in stewarding public money. The
CFPB does not aim for 100% competition, as the Bureau has a range of routine exempt service
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.
and supply needs, including follow-on efforts for web programming and cloud infrastructure
support, witness services, conferences, and subscriptions. In addition, the Office of Procurement
partners with the OMWI to develop tools and resources for increasing opportunities to minority
owned and women owned businesses.
In FY 2013, out of approximately $101 million that CFPB awarded in contracts, $84 million,
or 83%, were awarded on a competitive basis. By volume of contracts, 78% were awarded
competitively.
CFPB’s Office of Procurement met the target of 90% competitive awards for 45% of the
total procurement dollars that are managed internally. The CFPB utilizes the Bureau of the
Fiscal Service (BFS) for contracting support covering the remaining 55% of the procurement
spend.
BFS has a higher rate of direct awards, thus driving the overall percentage of contracts
competitively awarded in FY 2013 to 78%.
The CFPB will continue working strenuously inside the agency, as well as with the BFS partners, to
bring percentage of competitive awards in line with our ambitious goals for FY 2014 and FY 2015.
Performance goal 4.3.3: Distribute funds collected through enforcement
actions to identified victims within 24 months.
This goal tracks the disbursement of CPF payments and Bureau-administered redress funds
to eligible identified victims within 24 months of identifying victims. The Dodd-Frank Act
authorizes the CFPB to enforce Federal consumer financial laws. Under this authority, the CFPB
litigates cases which may result in redress to harmed consumers.
In some cases, the Bureau
will be responsible for obtaining redress funds from the defendant and distributing those funds
to the harmed consumers. In addition, the Dodd-Frank Act gives the Bureau the authority to
obtain civil money penalties in enforcement actions and to deposit those penalties in the Civil
Penalty Fund. It may then use amounts in the Civil Penalty Fund for payments to the victims of
activities for which civil penalties have been imposed.
PERFORMANCE MEASURE
Percentage of funds collected through the enforcement of Federal consumer financial laws that
is distributed within 24 months of identifying victims.
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
.
Targets
FY 2013: Baseline
FY 2014: TBD
FY 2015: TBD
Actuals
FY 2012: NA (the Bureau did not collect redress funds on behalf of victims in FY 2012)
FY 2013: Baseline under development
PROGRESS UPDATE AND FUTURE ACTION
In FY 2013, the Bureau took several key steps to build the infrastructure necessary to effectively
distribute redress and Civil Penalty Fund payments to eligible victims. Efforts included the
hiring of appropriate Bureau staff, the establishment of a formal Civil Penalty Fund allocation
process, and the hiring of vendors to manage distributions to victims. In November 2013, the
Bureau began distributing Civil Penalty Fund and redress funds to eligible consumers.
Outcome 4.4: Increase public confidence in consumer financial markets
by maintaining the CFPB’s transparency, accountability, and meaningful
channels for feedback.
Outcome leader: Associate Director, External Affairs
Since transparency is at the core of how the CFPB operates, the CFPB will provide clear
information both on the use of resources and on its performance. To that end, the CFPB
will communicate substantively and frequently across a wide range of external stakeholders,
including industry and consumer groups.
The CFPB aims to actively engage all stakeholders that
could potentially be affected by the Bureau, with the understanding that there is much insight to
be gained from varied stakeholders representing distinct points of view.
This outcome will be accomplished through the following
strategies and investments:
Strategies
§§ Gather input from stakeholders on the CFPB’s policies and operations to ensure the
Bureau is effectively communicating its activities, meeting transparency goals, and actively
soliciting feedback.
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. §§ Enhance program efficiency through regular analysis of operations data.
§§ Maintain and enhance a highly effective and usable online presence that supports multiple
digital services.
Investments
EXTERNAL STAKEHOLDER ENGAGEMENT
External Affairs’ budgets for FY 2014 and FY 2015 reflect investments to increase capacity to
allow the Bureau to solicit a broader range of perspectives from a wider variety of stakeholders,
to further amplify the Bureau’s work externally, and to coordinate, support, and inform the work
of the Bureau. External Affairs plans to continue to host public events in each of fiscal years
2014 and 2015 consistent with its strategic plan, to ensure that stakeholders and the public are
informed about the Bureau’s work and that the Bureau hears input and feedback from a diverse
range of external stakeholders.
We will assess our progress through the following performance
goal:
Performance goal 4.4.1: Engage the public by hosting public field
hearings, town hall meetings, Consumer Advisory Board meetings, and
other events on consumer finance issues.
The CFPB aims to engage with the public on consumer finance issues (a) to ensure that
consumers and interested parties have visibility into the Bureau’s work and have meaningful
opportunities to share input publicly and (b) to ensure that the Bureau’s work is informed by
regular input from varied perspectives representing distinct points of view.
PERFORMANCE MEASURE
Number of public field hearings, town hall meetings, Consumer Advisory Board meetings, and
other public events hosted annually
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. Targets
FY 2013: 8 Events
FY 2014: 9 Events
FY 2015: 9 Events
Actual
FY 2012: 8 Events
FY 2013: 11 Events
PROGRESS UPDATE AND FUTURE ACTION
The Bureau held 11 public events in FY 2013 focused on key issues affecting consumer financial
markets such as mortgages, debt collection, and student financial products. These included
three meetings of its Consumer Advisory Board (CAB).
1. Seattle field hearing in October of 2012 on debt collection
2. Silicon Valley public event in November of 2012 on Project Catalyst
3. Baltimore field hearing in January of 2013 on Qualified Mortgages
4. Atlanta field hearing in January of 2013 on mortgage servicing
5. Washington DC CAB meeting in February of 2013
6. Des Moines field hearing in March of 2013 on consumer complaints
7. Los Angeles CAB meeting in May of 2013
8. Miami field hearing in May of 2013 on student lending
9. Portland, Maine field hearing in July of 2013 on debt collection
10. Itta Bena, Mississippi CAB meeting and public panel discussion in September 2013
11. Washington DC public forum in September of 2013 on college banking products
The Bureau also participated in dozens of public events hosted by others, including testifying
before Congress on 16 occasions during FY 2013 to discuss policy, operations and budget
matters. In FY 2014 and beyond, the Bureau will continue to host events on issues impacting
financial consumers, including mortgages, student loans, and other issues. The Bureau will also
continue to testify on important issues at the request of Congress.
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.
Appendix A:
Program evaluations
The CFPB has an expansive, vital mission yet limited resources to achieve its goals. Our vision
helps to guide us in the right direction; our values set expectations for how we get there; and our
strategy helps to focus our energies on areas that offer the greatest potential impact.
It is also important for us to step back, evaluate our recent past performance, and plan for
that which is to come. In order to ensure the Bureau’s programs and strategies are effectively
achieving its goals, the Bureau uses a variety of processes and reports to periodically evaluate its
performance and course correct when necessary.
GOVERNMENT ACCOUNTABILIT Y OFFICE
The GAO conducts studies or investigations related to the CFPB’s programs every year. In FY
2012, GAO’s reports included studies on the benefits and costs associated with implementing the
Dodd-Frank Act; the Dodd-Frank Act’s impact on community banks and credit unions, troubled
mortgages and the Troubled Asset Relief Program; and, the operations of the Financial Stability
Oversight Council and the Office of Financial Research, among other areas.
In addition, GAO
performs an annual audit of the CFPB’s financial statements and internal controls, as required
by the Dodd-Frank Act.
OFFICE OF THE INSPECTOR GENERAL OF THE BOARD OF GOVERNORS OF THE FEDERAL
RESERVE SYSTEM AND THE CONSUMER FINANCIAL PROTECTION BUREAU
The OIG is an independent oversight authority within the Board of Governors of the Federal
Reserve System that conducts audits, inspections, evaluations, and other reviews of programs
and operations of the CFPB and investigations into allegations of potential misconduct by staff
or contractors. The mission of the OIG is to detect fraud, waste and abuse, and to promote
integrity, economy, efficiency and effectiveness in the CFPB’s programs and operations. The
OIG’s audit reports are available on the OIG’s website.
INDEPENDENT PERFORMANCE AUDIT
In accordance with the Dodd-Frank Act, the CFPB orders an annual independent audit of the
operations and budget of the Bureau.
The purpose of this audit is to provide objective analyses
to improve program performance and operations, reduce costs, facilitate decision-making, and
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. contribute to public accountability. The audits for prior years are available on the Bureau’s
website.
QUARTERLY PERFORMANCE REVIEWS
On a quarterly basis, the CFPB executives, including all Goal Leaders, review progress toward
achieving the Bureau’s strategic goals and outcomes, in part using the performance goals and
measures outlined in this plan. At these points, course corrections are made as needed.
External consultation
In accordance with statute, the Bureau sought input from Congress on its Strategic Plan several
times during the drafting process. In addition, the Bureau posted the Strategic Plan on its
website for 30 days in order to give the public the opportunity to provide comments.
Verification of performance data
The CFPB will strive to ensure that the information reported in performance documents and the
processes used to develop that information are complete and reliable.
As an example of existing
validation and verification processes, the Bureau is subject to an annual independent audit of
operations and budget, as required by Sec. 1573 of Public Law 112–10, which includes a review of
the CFPB’s performance-based budgeting processes and data validation and verification policy
and procedures.
In its FY 2013–2017 Strategic Plan, the CFPB is establishing a number of new performance
measures in order to assess progress. In some instances, the Bureau does not have sufficient
data in order to set targets for FY 2014 and FY 2015.
In these cases, the Bureau either has
already established or will establish baselines by the end of FY 2014, and set targets starting in
FY 2014 and 2015 as applicable.
External factors
Key external factors beyond the Bureau’s control have the potential to impact the CFPB’s ability
to effectively achieve its strategic goals and objectives.
It is anticipated that markets in both the U.S. and foreign financial services sectors will evolve
over time. These future changes must be monitored, as they will impact the work of the CFPB in
protecting consumers and addressing a continually changing financial environment.
Additional external factors are discussed throughout the Strategic Plan in the context of our
goals and outcomes.
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.
Management challenges
The United States Congress, in implementing the Dodd-Frank Act, followed a long-established
precedent and provided the CFPB with funding outside of the congressional appropriations
process to ensure full independence as the Bureau supervises and regulates providers of
consumer financial products and services and protects consumers. Congress has consistently
provided for independent funding for bank supervisors to allow for long-term planning and the
execution of complex initiatives and to ensure that banks are examined regularly and thoroughly
for compliance with the law.
The CFPB supervises over 100 very large depository institutions, including the largest, most
complex banks in the country. In addition, it has been charged by Congress with responsibility
for supervising thousands of nonbank providers of consumer financial products and services.
Effective supervision that assures a level playing field between bank and nonbank institutions
requires dedicated and predictable resources, and independent examiners.
Although Congress provided the CFPB with a source of funding outside the appropriations
process, the CFPB is nonetheless the only bank supervisor with a statutory cap on its primary
source of funding. If the Director were to determine that the non-appropriated funds to which
it is entitled under the Dodd-Frank Act are insufficient to carry out its responsibilities, section
1017 (e) of the Dodd-Frank Act authorizes the CFPB to also obtain appropriated funds through
FY 2014, up to a capped amount and subject to apportionment.
In accordance with the DoddFrank Act and appropriations law requirements, further action would be required on the part
of the Director and Congress in order for the CFPB to obtain such appropriated funds. These
additional funds would be subject to apportionment under section 1517 of Title 31, United States
Code, and restrictions that generally apply to the use of appropriated funds in Title 31, United
States Code, and other laws.
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. Appendix B: ORGANIZATIONAL CHART
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
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CFPB STRATEGIC PLAN, BUDGET, AND PERFORMANCE PLAN AND REPORT
. consumerfinance.gov
Consumer Financial Protection Bureau
1700 G Street NW
Washington DC 20552
855-411-CFPB (2372)
TTY/TDD 855-729-CFPB (2372)
cfpb_design@cfpb.gov
.