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Consumer Financial Protection Bureau (CFPB)
Financial Services Omnibus Contract #: TOFS-11-D-0001 Task Order #: CFP-11-K-00021
Independent Performance Audit of CFPB Operations and Budget
Submitted October 15, 2011 by:
ASR Analytics, LLC Federal TIN: 20-1204680
1389 Canterbury Way DUNS: 15-108-3305
Potomac, MD 20854 www.asranalytics.com
Submitted to:
Consumer Financial Protection Bureau
Ms. Antona Lilly (antona.lilly@cfpb.gov)
1801 L Street, NW
Washington, DC 20036
1389 CANTERBURY WAY POTOMAC, MD 20854 PHONE: 301‐738‐9502 www.asranalytics.com
October 15, 2011 Mr. Raj Date Special Advisor to the Treasury Secretary for the Consumer Financial Protection Bureau Consumer Financial Protection Bureau 1500 Pennsylvania Ave. NW Attn: 1801 L Street NW Washington, DC 20036 Dear Mr. Date:
On behalf of ASR Analytics, LLC (ASR), I am pleased to enclose the attached report, which presents the results of our independent performance audit of the Consumer Financial Protection Bureau (CFPB). This audit was commissioned by the CFPB in accordance with the Full-Year Continuing Appropriations Act, 2011 (Pub. L. 112-10) of April 15, 2011, Title V, Section 1573 (a), which amended the Dodd-Frank Wall Street Reform and Consumer Protection Act to require an annual independent audit of the operations and budget of the bureau (12 USC 5496a). ASR performed this work between August 19, 2011 and October 15, 2011.
For this performance audit, ASR reviewed the operations of five key areas, which CFPB identified as instrumental in implementing the Consumer Protection Act of 2010 and standing up the CFPB as an organization: (1) Human Capital and Organizational Development; (2) Consumer Response; (3) Information Technology; (4) Communications and Transparency; and (5) the CFPB budget. To evaluate the CFPB’s operations and performance in these five areas, we relied on a combination of physical, documentary, and testimonial evidence, most of which was provided by the CFPB. We reviewed more than 250 artifacts, including policy and planning documents, status reports, briefing memos, meeting minutes, discussion decks, statements of work, and other sources. In addition, we held over 50 meetings with CFPB personnel and other stakeholders.
A draft of this report was shared with all participating stakeholders at the CFPB for review and comment. CFPB staff provided us with oral and written comments on the draft report, including several technical clarifications and suggestions, which we incorporated where appropriate.
If you have any questions about this report, please contact me at 608-467-7291 or Michael Stavrianos at 301-758-0371. Other key contributors to this report include Peter Arena, Edward Hau, Michele Lebar, Edward Merrill, Sarah Sheehan, Melissa Toledo, and Tucker Warren.
Sincerely,
Stephen Rhody Founding Principal ASR Analytics, LLC cc: Ms. Catherine West, Chief Operating Officer, Consumer Financial Protection Bureau
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Table of Contents Section 1: Executive Summary ............................................................................................................... 1
1.1 Background ............................................................................................................................... 1
1.2 Compliance with Government Auditing Standards ................................................................ 1
1.3 Organization of this Report ...................................................................................................... 2
1.4 Findings and Recommendations .............................................................................................. 3
Section 2: Human Capital and Organizational Development .......................................................... 11
2.1 Scope of Audit ........................................................................................................................ 11
2.2 Evaluation Criteria .................................................................................................................. 12
2.3 Findings and Recommendations ............................................................................................ 14
Section 3: Consumer Response ............................................................................................................. 27
3.1 Scope of Audit ........................................................................................................................ 27
3.2 Evaluation Criteria .................................................................................................................. 29
3.3 Findings and Recommendations ............................................................................................ 32
Section 4: Information Technology ...................................................................................................... 49
4.1 Scope of Audit ........................................................................................................................ 49
4.2 Evaluation Criteria .................................................................................................................. 50
4.3 Findings and Recommendations ............................................................................................ 55
Section 5: Communications and Transparency ................................................................................. 65
5.1 Scope of Audit ........................................................................................................................ 65
5.2 Evaluation Criteria .................................................................................................................. 65
5.3 Findings and Recommendations ............................................................................................ 69
Section 6: Budget .................................................................................................................................. 109
6.1 Scope of Audit ...................................................................................................................... 109
6.2 Evaluation Criteria ................................................................................................................ 110
6.3 Findings and Recommendations .......................................................................................... 113
Appendix A: List of CFPB Officials who Provided Input ....................................................................... 125
Appendix B: List of Acronyms ..................................................................................................................... 127
Appendix C: Audit Team ............................................................................................................................... 129
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
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Section 1: Executive Summary
1.1 Background
This report presents the results of an independent performance audit of the Consumer Financial Protection Bureau (CFPB) – commissioned by the CFPB in accordance with the Full-Year Continuing Appropriations Act, 2011 (Pub. L. 112-10) of April 15, 2011, Title V, Section 1573 (a) – which amended the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) to add the following text:
(a) Annual Independent Audit.--The Bureau shall order an annual independent audit of the operations and budget of the Bureau.
(b) Annual GAO Audit.--The Comptroller General of the United States shall conduct an annual audit of the Bureau's financial statements in accordance with generally accepted government accounting standards.
In order to meet this requirement, the CFPB must order an independent performance audit for FY 2011, and complete the report by October 15, 2011. For this performance audit, the bureau identified five key areas of operations, which were instrumental in implementing the Consumer Protection Act of 2010 and standing up the CFPB as an organization: (1) Human Capital and Organizational Development; (2) Consumer Response; (3) Information Technology; (4) Communications and Transparency; and (5) the CFPB budget.
It is important to note that this is a performance audit, not a financial audit, and thus does not overlap with the Annual GAO Audit described in Sec 1573 (a). Performance audits are engagements that provide findings or conclusions based on an evaluation of sufficient, appropriate evidence against defined criteria. Their purpose is to provide objective analysis to assist management in using the information to improve program performance and operations, reduce costs, facilitate decision making, and contribute to public accountability.
1.2 Compliance with Government Auditing Standards
We conducted this performance audit in accordance with generally accepted government auditing standards (GAGAS), with one exception. Namely, while all members of the audit team maintain professional competence in their respective areas of specialization, some members have ongoing efforts to achieve minimum hours of continuing professional education that directly relates to government auditing. This exception notwithstanding, we believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.
Information for this performance audit was derived from physical evidence, documentary evidence, and testimonial evidence, most of which was provided by the CFPB. We reviewed more than 250 artifacts over the course of this study, including policy and planning documents, status reports, briefing memos, meeting minutes, discussion decks, statements of work, and other sources. In addition, we held over 50 meetings with CFPB personnel and other stakeholders.
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1.3 Organization of this Report
Section 1 of this report is an Executive Summary. Subsequent sections present the results of our performance audit for each of the five operational areas. Section 2 focuses on Human Capital and Organizational Development; Section 3 on Consumer Response; Section 4 on Information Technology; Section 5 on Communications and Transparency; and Section 6 on Budget. Appendix A provides a list of CFPB officials who provided input to this audit; Appendix B presents a list of acronyms used in this report; and Appendix C offers a brief overview of our audit team.
Within each section, we present information on three topics: (1) audit scope; (2) evaluation criteria; and (3) findings and recommendations. Below, we summarize the information addressed within each of these topics.
1.3.1 Scope of Audit
Due to the time constraints for this performance audit, as well as the short history of the CFPB as an organization, the scope of this performance audit is necessarily limited. The purpose of this section is to define the overall scope of the review area and to enumerate the performance elements that are within the scope of this audit. The audit scope defines the subject matter that the auditors have assessed and reported on, such as a particular business process, organizational unit, or technology system. If applicable, this section also describes any significant constraints imposed on the audit due to information limitations or other scope impairments.
1.3.2 Evaluation Criteria
The purpose of this section is to describe the criteria that are used to evaluate performance. Audit criteria represent the laws, regulations, standards, requirements, measures, and benchmarks against which performance is compared or evaluated. Our audit focused on three sets of criteria: (1) compliance with the legal requirements; (2) achievement of organizational goals; and (3) alignment with performance standards, best practices, and/or benchmarks. These criteria are consistent with GAO standards for evaluation criteria, as published in August 2011 (Government Auditing Standards, 2011 Internet Version, Section A6.02). Within each section of this report, we identify the audit objectives and evaluation criteria that are specific to each review area—and we cite specific evaluation frameworks and/or methodologies that are used to support the evaluation. In order to establish a broad basis for evaluation, we rely (where possible) on established “performance frameworks”, which define a set of commonly accepted performance standards and associated criteria or metrics. For example, in the Human Capital and Organizational Development review area, we use the Human Capital Assessment and Accountability Framework (HCAAF) to establish performance standards and evaluation criteria.
1.3.3 Findings and Recommendations
Within each section, we evaluate the CFPB’s performance with respect to three sets of criteria—legal requirements, organizational goals, and performance standards. Our findings and recommendations are presented in two ways. First, within the body of the report, we provide a bulleted list of the findings and recommendations that we view as most important. Second, in a series of detailed tables, we describe the progress that the bureau has demonstrated to date with respect to each performance
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criterion, and we offer recommendations for future action. In these tables, we further characterize the bureau’s performance using “stoplight ratings” and “priority scores”, as defined below. Stoplight Ratings
Green (G): Performance to date has met or exceeded the auditor’s expectations for a new organization in all relevant criteria. CFPB has fully achieved the performance element or has made significant progress towards achieving it.
Yellow (Y): Performance to date has met the auditor’s expectations for a new organization in some but not all relevant criteria. CFPB has made progress towards achieving the performance element, but additional attention is needed.
Red (R): Performance to date has not met the auditor’s expectations for a new organization. CFPB has not made any significant progress towards achieving the performance element.
Blank (–): No expectations exist with respect to this performance element. CFPB is not expected to have demonstrated any performance in this area at this time in its standup.
Grey (?): The audit team did not receive enough information to evaluate performance at this
time.
Priority Scores
High: This is a high priority for meeting the bureau’s goals. Action should be taken as soon as possible.
Medium: This is a medium priority for meeting the bureau’s goals. Action should be taken within the next 6 months.
Low: This is a low-level priority for meeting the bureau’s goals. Nevertheless, action plans should be developed within the next year.
1.4 Findings and Recommendations
1.4.1 Summary of Performance Ratings
Across all five review areas, the CFPB has made significant progress towards achieving legal compliance, attaining organizational goals, and meeting performance standards. Through this performance audit, we rated the bureau’s performance with respect to 102 distinct performance elements. As illustrated in the figure below, the CFPB achieved a Green stoplight rating (met or exceeded expectations in all relevant criteria) for 67 (66%) of these performance elements—and achieved a Yellow rating (met expectations in some relevant criteria) for 24 (24%) of these elements.
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None of the elements received a Red score (performance has not met expectations). Following the summary table, we highlight key findings and recommendations from each of the five review areas.
Performance Rating Human Capital
Consumer Response
Information Technology Communications Budget
All Review Areas
5 (38%) 6 (33%) 6 (60%) 47 (81%) 3 (100%) 67 (66%)
7 (54%) 8 (44%) 2 (20%) 7 (12%) 0 (0%) 24 (24%)
0 (0%) 0 (0%) 0 (0%) 0 (0%) 0 (0%) 0 (0%)
0 (0%) 3 (17%) 2 (20%) 1 (2%) 0 (0%) 6 (6%)
1 (8%) 1 (6%) 0 (0%) 3 (5%) 0 (0%) 5 (5%)
1.4.2 Key Findings and Recommendations: Human Capital and Organizational Development
CFPB fully complied with the requirement to develop a Recruitment and Retention Plan, Training and Workforce Development Plan and Workforce Flexibilities Plan. CFPB delivered these plans to Congress on July 21, 2011, as part of the report Developing our Human Capital. The document identifies achievements as well as near and longer term actions in each of the three requirement areas.
CFPB met the requirement of the Dodd-Frank Act to develop a compensation and benefits program. CFPB benchmarked the Federal Reserve Board and other Financial Institutions Reform Recovery and Enforcement Act (FIRREA) agencies to come up with a comparable and competitive compensation model to attract mission-critical and support occupations.
CFPB should staff up the bureau’s leadership positions and core functions. This goal is mostly complete. To date, 4 of the 6 Associate Directors are on board and 20 of the 36 Assistant Directors are on board. Going forward, it is important to continue the search to fill needed leadership positions in a timely manner.
CFPB has transferred employees from other federal agencies to address mission-critical staffing needs. CFPB identified the major mission-critical and supporting functional positions required, and negotiated with six federal agencies for positions to support mission-critical functions being transferred to CFPB. A memorandum of understanding (MOU) was developed that specifies the agreement with the federal agencies to transfer employees into CFPB. An ‘Expression of Interest’ was implemented with federal agencies, and interviewing and selection criteria were outlined in MOUs, resulting in 232 transferees into CFPB.
CFPB should continue to implement its recruitment strategy. CFPB has done an excellent job at filling positions to stay on target with recruiting goals and should continue aggressive recruiting efforts through FY 2012 to hire the balance of personnel to staff CFPB at
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its targeted level. It is important that the bureau follow through by implementing its recruitment strategy, vision and goals stated in the September 23, 2011 presentation CFPB Recruitment Strategy & Update. There are over 400 mission critical vacancies and a number of outreach activities that have been identified for FY 2012. Dedication, commitment, coordination and expertise will be needed at all levels to accomplish these actions.
CFPB should fully develop a Training and Workforce Development Plan. The Dodd-Frank Act specifically calls for a Training and Workforce Development plan, and this continues to be a high priority and immediate need for CFPB. In the Annual Report to Congress on July 21, 2011, Developing our Human Capital, CFPB defined an approach to training and workforce development. To support their mission, CFPB has developed and held lunch and learns, on-boarding training, and approximately three weeks of training for the core Examiner and Consumer Response workforces. An assessment of workforce skills has been executed and core competencies for executives and non-executives have been developed. CFPB has a longer term goal to develop as a learning organization. In the near term, the Training and Workforce Development Plan should ensure that CFPB has a consistent and unified approach to training and workforce development, across all units and employee populations.
1.4.3 Key Findings and Recommendations: Consumer Response
CFPB’s Consumer Response function has complied with all relevant legal requirements. CFPB should use the credit card complaint standup approach – and learnings derived from its initial implementation – as a template of sorts as Consumer Response continues to expand its scope beyond the credit complaint area into mortgages and other financial products/services.
Consumer Response is in compliance with its own internal organizational performance targets in those areas where: (1) targets have been documented; and (2) CFPB has officially begun holding itself and others to performance targets that have been set thus far. CFPB should complete the standup of key remaining operational enablers. This includes launching Consumer Response’s consumer-facing knowledge base, implementing its complex case management system, and ramping up to at least minimum analyst staffing levels required to support quality assurance reviews for CFPB investigations and to develop/execute a master performance dashboard.
CFPB should finalize all remaining targets tied to major operational metrics – and begin enforcing targets as soon as possible. Consumer Response has yet to establish and/or enforce final targets for operational metrics like maximum bank/regulator response time during CFPB investigations, or standards around frequency and scope of periodic quality assurance analysis and reporting (outside the intake/call center area). The sooner CFPB establishes targets for these critical activity areas, the sooner it can begin tracking performance associated with the full scope of its mandate, and the better prepared it will be to provide periodic reporting and analysis to other stakeholders.
CFPB should consider adding consumer resolution dispute rate to its featured short-list of major operational metrics. Including this metric (i.e., % of “resolved” complaints that
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consumers subsequently dispute) can increase leadership visibility into what affected consumers may perceive as the effectiveness of current Consumer Response processes, and help uncover themes and/or emerging issues in individual bank investigation performance.
CFPB should establish a single Consumer Response master dashboard to track and communicate actual performance against targets. This master dashboard may contain different tabs/views, covering either department-wide (standup) goals or goals specific to each financial product CFPB eventually addresses. Generally, however, the goal should be to minimize differences across dashboard views to ensure appropriate focus on the core elements of Consumer Response’s mission, and to facilitate easy comprehension and interpretation of performance data.
CFPB should implement an OMB-approved consumer satisfaction survey as a basic means to begin systematically collecting feedback directly from those who are experiencing CFPB’s operations today.
CFPB should leverage the feedback it is already collecting. As an example, the bureau should establish operational goals and processes around mining contacts that are currently stored in Consumer Response’s contact management system as “feedback.”
CFPB should draft a more formal “stakeholder feedback platform” plan. The bureau should whiteboard current feedback mechanisms by key operational areas, (e.g., intake, routing, tracking/resolution, analysis), channels (e.g., website, toll-free number), and stakeholder type (e.g., prudential regulators, covered persons, consumer advocacy groups, mass consumer audiences). In order to test the relevance and value of these feedback mechanisms, CFPB should consider who will use the feedback from each data stream, how the feedback will be used, and what the bureau [or other relevant stakeholders] will do differently as a result of this feedback.
CFPB should complete the conceptual development of a feedback platform, secure approvals as needed and begin to implement. Note that “approvals” in this case means both completing relevant compliance activity (e.g., Paperwork Reduction Act-mandated work), but also securing buy-in from other CFPB offices or other key stakeholders to utilize insight generated from the feedback that Consumer Response collects and analyzes.
CFPB should continue to enhance process transparency to consumers and other stakeholders. One way to accomplish this goal is to leverage stakeholder feedback, in order to enhance the clarity of CFPB processes and performance expectations in ways that are relevant to each major stakeholder group. For consumers, one relatively quick “win” in this area would be to build notification capability to alert complainants as investigations move through CFPB’s tiers.
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1.4.4 Key Findings and Recommendations: Information Technology
CFPB has used Information Technology (IT) to support customer service. With the development of the Consumer Information System (CIS) and the CFPB website, the IT department has created an engaging digital experience. The use of “Tell Your Story” and “Know Before You Owe” on the website offer further evidence of progress in this area. We recommend that the IT organization continue its emphasis on this goal and conduct a formal review of the usability of the website.
CFPB has aligned its information technology assets with its strategic missions, in accordance with the Clinger-Cohen Act of 1996. This alignment is managed by the Investment Review Board (IRB), and documented at a high level through the IRB dashboard. Specifically, the IRB dashboard identifies each of the Initial Systems (technology assets) being developed by CFPB, and links each asset to either: (1) a specific element of CFPB’s mission; or (2) a specific enterprise or business service.
CFPB has complied with key elements of the E-Government Act of 2002, including the Federal Information Security Management Act (FISMA) and the Confidential Information Protection and Statistical Efficiency Act (CIPSEA). Specifically, CFPB obtained authority to operate (ATO) for: (1) connectivity to the Treasury infrastructure; and (2) protection of confidential and/or personal information in CIS. We recommend that CFPB continue their approach to retaining personal information and conducting FISMA audits. CFPB has already demonstrated behaviors consistent with this, for example, by submitting System of Record Notices (SORN) that address items such as the individuals covered by the system, categories of records in the system, purpose of the system, categories of users of the system, storage, retrievability, and safeguards.
CFPB should continue to build human capital for the IT function. CFPB has made appropriate progress towards this goal. It has named a Chief Technology Officer, Chief Information Officer and Chief Information Security Officer – and it has established a productive IT organization through an integrated team of government and contractor personnel. We recommend that the IT organization target an 8% to 10% ratio of IT staff to total CFPB staff.
CFPB should form an IT program management office (PMO) to facilitate a continuation of its customer focus and implementation of key systems. Adopting a PMO approach would provide a means of standardizing artifacts across projects and facilitate development of a project database to support evaluations and a “lessons learned” process.
CFPB should initiate a formal evaluation process for IT investments. We found that the
project selection and project control components of CFPB’s IT investment management process met GAO standards, as defined in the Information Technology Investment Management (ITIM) Framework. We recommend that CFPB initiate a formal investment evaluation process, now that it has a growing set of historical data regarding the performance of IT projects. The evaluation process should be a function of the IRB and supported by the PMO.
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CFPB’s IT investment management process is operating at “stage two” of the five-stage
maturity model defined by the GAO’s ITIM Framework. In order to progress to stage three, CFPB should build upon existing IRB processes, with an emphasis on: (1) grouping similar investments together and developing an IT portfolio; (2) creating and maintaining portfolio selection criteria; (3) examining the merits of each IT investment in the context of the portfolio; and (4) using an Enterprise Architecture to help align IT investments with strategic objectives.
CFPB should develop and apply standard methods to manage risk and cost variance for IT investments. Using the Federal IT Dashboard as a performance standard to evaluate three projects, we found evidence of good requirements management, contractor oversight, human capital, and schedule management. We recommend that the IT department apply a standard method to monitor and manage cost variance, even though many projects are performed on a fixed cost basis. Also, we recommend that CFPB adopt a standardized approach to documenting risks and mitigation strategies.
1.4.5 Key Findings and Recommendations: Communications and Transparency
CFPB should continue to move toward filling positions and offices mandated by the Dodd-Frank Act. The Dodd-Frank Act mandated the creation of six offices that perform communications functions. CFPB has fulfilled its statutory mandates with respect to these positions. The CFPB is statutorily unable to create a Consumer Advisory Board (CAB) until a Director has been approved by Congress. However, a detailee is on staff currently serving in the Ombudsman role, which does not require a Director in place. In addition to filling the Ombudsman position with a permanent employee as soon as possible, we recommend that CFPB continue to move forward with developing plans for CAB and be prepared to staff positions as soon as a Director is approved.
CFPB should further coordinate its mission, vision and values statements across mediums. Currently, the CFPB has defined its mission, vision and values, but they differ slightly across platforms. While slight variances are to be expected given the differing audiences each CFPB office is trying to reach (e.g., lawmakers, consumers and the general public), in places where the CFPB’s statutory purpose, mission, vision, and values are printed, it should consider reducing inconsistencies. Doing so will build brand strength over time and allow multiple audiences to fully understand how the CFPB views itself.
CFPB should continue work on developing additional language capabilities. The CFPB has made efforts to engage populations that have been most severely impacted by the financial crisis. Currently the CFPB offers its 800 number in 189 languages and is in the process of co-developing a Spanish version of the new single mortgage disclosure document from the Know Before You Owe initiative and a fully functional Spanish version of the website. Co-developing materials takes longer but it creates a much better product for consumers. CFPB should continue to move forward in developing additional language capabilities to allow all of its key constituencies to participate in the dialogue.
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CFPB should maintain policymaker interaction. Discussions with CFPB stakeholders revealed a proactive view toward interacting with policymakers, including members of Congress, and state and local officials. Members of the CFPB team have testified before Congress on eleven occasions, have made numerous trips to the Hill to brief both Congressional staff and members of Congress, and regularly provide updates on news coming out of the bureau. CFPB should continue to engage policymakers and work toward establishing a two-way dialogue through which both the bureau and policymakers can gain important insight from one another.
CFPB should continue to engage key audiences. One of the challenges for the CFPB as it
continues to grow, mature and assume more responsibility is to continue the high level of engagement it has fostered thus far. The bureau has set a very high standard for itself and may encounter difficulties living up to that standard. An increase in staff will assist in meeting the growing responsibilities of the bureau in this area.
CFPB should develop searchable content capability. One of Community Affairs’ goals is
to have searchable resource content available for all reports, studies and communications with key groups. Community Affairs is currently working with the IT department to develop the digital infrastructure needed for such a resource. CFPB should continue to develop this capability.
1.4.6 Key Findings and Recommendations: Budget
CFPB has addressed all relevant budgeting requirements under Title X of the Dodd-Frank Act. Overall, we found that CFPB practices are documented and consistently performed.
CFPB should complete policy and procedural documentation. CFPB should continue its work underway to more-fully document policies related to critical aspects of the Federal Reserve funding request and transfer process. In addition, CFPB should continue to more-fully document policies related to budget formulation and execution / commitment control. Supplemental documentation should be developed to define detailed funding and budgetary procedures, roles and responsibilities, and performance management and monitoring practices.
CFPB should build a staffing plan for the budget organization. CFPB has been hiring additional budget staff over the past several months. As the bureau continues to expand its operations, we encourage the bureau to continue to reach out to other comparable U.S. federal agencies that have unique funding mechanisms and missions similar to that of CFPB (e.g., FDIC and OCC) to garner ideas and recommendations for the structure and staffing levels of the bureau’s budgeting operations.
CFPB should continue to expand transparency of funding and expenditures. As the CFPB grows, we expect the bureau will continue to expand the amount of information available to the public (e.g., operational plans, funding levels, expenditures, financial performance management against bureau priorities, and the like).
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CFPB should increase automation of budget formulation and performance management. As is expected, much of CFPB’s budget formulation process is manual and leverages spreadsheets – some of which are quite large and complex. CFPB should continue comparative analysis with other similar agencies to evaluate options for enhanced budget formulation and performance management automation. Where possible, we recommend leveraging pre-existing solutions to best serve the bureau at this stage of its evolution versus developing a bureau-specific solution.
CFPB should continue to clarify and document the applicability of budget-related Circulars and Acts. CFPB continues its efforts to clarify and document the applicability to CFPB operations of various budgeting and performance management Circulars and Acts. CFPB has already adopted and will continue to integrate into its operations the principles and concepts contained within the relevant Circulars and Acts and the bureau will implement, where possible, best practice components. We support the bureau’s plans to both document and implement all applicable standards and best practices.
CFPB should incorporate “outcome” objectives in its strategic planning. We understand bureau-wide strategic plans are under development within CFPB. While this performance audit did not evaluate the progress nor content of the current draft plans, we encourage CFPB’s progressive stages of strategic planning to incorporate Government Performance and Results Act (GPRA) Modernization Act of 2010 (Public Law 111-352 or GPRA-MA) concepts outlining high-level organizational priorities, “outcome” objectives, annual performance management plans, the relationship to funding and budgetary plans, progress review plans, accountability assignments, and plans for transparent monitoring and reporting.
CFPB should load its budget at a divisional level. Starting with the FY 2013 President’s Budget (currently being formulated) and the FY 2012 Operations Plan for CFPB, the bureau plans to construct its budget on a bottom-up basis by cost center. For the FY 2012 Operations Plan, CFPB plans to load its budget in its financial management system on a divisional basis for enhanced execution and control. We support the bureau’s plan to begin loading the budget at a divisional level in FY 2012 for more effective management, control and accountability.
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Section 2: Human Capital and Organizational Development
2.1 Scope of Audit
In this section, we establish scope boundaries for our audit of CFPB’s performance in the area of Human Capital and Organizational Development. In order to define the overall scope of this review area, we look to standards established by the Office of Personnel Management (OPM)’s Human Capital Assessment and Accountability Framework (HCAAF). The HCAAF establishes and defines five human capital systems that together provide a single, consistent definition of human capital management for the Federal Government. Moreover, the HCAAF outlines an ongoing process of human capital management for Federal agencies. This framework is used to maximize planning and goal setting, implementation, and evaluation of results across the following five systems:
1. Strategic Alignment (Planning and Goal Setting). Led by senior management—typically the Chief Human Capital Officer (CHCO)— to promote the alignment of human capital management strategies with bureau mission, goals, and objectives through analysis, planning, investment, measurement, and management of human capital programs.
2. Leadership and Knowledge Management (Implementation). Ensures continuity of leadership by identifying and addressing potential gaps in effective leadership, and implements and maintains programs that capture organizational knowledge and promote learning.
3. Results-Oriented Performance Culture (Implementation). Promotes a diverse, high-
performing workforce by implementing and maintaining effective performance management systems and awards programs.
4. Talent Management (Implementation). Addresses competency gaps, particularly in
mission-critical occupations, by implementing and maintaining programs to attract, acquire, develop, promote, and retain quality talent.
5. Accountability (Evaluating Results). Contributes to bureau performance by monitoring and
evaluating the results of its human capital management policies, programs, and activities; by analyzing compliance with merit system principles; and by identifying and monitoring necessary improvements.
Given its brief organizational history, it is not expected that the CFPB would have demonstrated progress across all of the systems defined by the HCAAF. Indeed, when standing up a new organization, there are generally some human capital systems and processes that are implemented prior to others. With that in mind, the scope of our audit is limited to three of the five HCAAF dimensions: Leadership and Knowledge Management; Results-Oriented Performance Culture; and Talent Management.
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The other two dimensions (Strategic Alignment and Accountability) are generally matured once an organization has established foundational human capital systems. Strategic plans for the CFPB are expected to be developed in FY 2012. The development of the strategic plan will align the mission, goals and objectives of the bureau and establish how the human capital organization will be analyzed. Accountabilities will also be developed to support analysis of program performance. In cases where the CFPB has already demonstrated progress or documented future-state plans, those activities are mapped to the corresponding HCAAF dimension, and performance is evaluated relative to established criteria. For those HCAAF dimensions where the bureau has not yet demonstrated progress, the performance audit provides general recommendations regarding: (1) target dates for achieving specific milestones in these dimensions; (2) best practices with respect to performance in these dimensions; and (3) future audits of performance in these areas. As an example, each agency is required by OPM to prepare a Strategic Human Capital Plan (SHCP) and a Human Capital Management Report (HCMR). CFPB is not required to submit the SHCP this year but is required to submit an HCMR documenting the bureau’s progress on December 15th. Thus, while a review of the SHCP is out of scope for this audit, we provide guidance regarding best practices in the development of this plan, as well as recommendations for prospective audits of performance.
2.2 Evaluation Criteria
The purpose of this section is to describe the evaluation criteria for this review area (associated findings and recommendations are presented in Section 2.3). As with other areas of performance, our audit focuses on three sets of criteria: (1) compliance with legal requirements; (2) achievement of organizational goals; and (3) alignment with performance standards, best practices, and/or benchmarks.
2.2.1 Compliance with the Law
In order to assess compliance with legal requirements, we evaluate the extent to which CFPB has met each of the following legal requirements, established by the Dodd-Frank Act and other relevant legislation.
Section 1067 of the Dodd-Frank Act requires the bureau to submit an annual report to the
Committee on Banking, Housing, and Urban Affairs of the Senate and the Committee on Financial Services of the House of Representatives that includes: (1) a Recruitment and Retention Plan; (2) a Training and Workforce Development Plan; and (3) a Workforce Flexibilities Plan.
Section 1013 of the Dodd-Frank Act requires that, “The Director shall at all times provide compensation (including benefits) to each class of employees that, at a minimum, are comparable to the compensation and benefits then being provided by the Board of Governors for the corresponding class of employees.”
Pursuant to the Dodd-Frank Act, the CFPB has collaborated with the six transferring agencies to establish procedures and systems that allow for employees transferring into the bureau to retain appropriate benefits provided to them by their prior agency for a one-year period, and to reimburse those agencies as required by the Dodd-Frank Act. The six agencies are the
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
13
Department of Housing and Urban Development, Office of Thrift Supervision, Office of the Comptroller of the Currency, National Credit Union Administration, Federal Deposit Insurance Corporation, and the Federal Reserve Board of Governors and Federal Reserve System Banks.
Under the Dodd-Frank Act CFPB must establish business units in the areas of research, community affairs and collecting and tracking complaints. The Dodd-Frank Act states that the following offices should be developed within one year of the designation transfer date of July 21, 2011 to include, fair lending and enforcements, financial education, servicemembers affairs; and within 180 days of the transfer date, offices such as, financial protection for older Americans and minority and women inclusion, ombudsman, and consumer advisory board should be established.
2.2.2 Achievement of Organizational Goals
In order to assess achievement of organizational goals, we evaluated the progress that CFPB has made towards measurable goals that are documented in the bureau’s planning artifacts. The bullets below describe the four organizational goals that were provided by CFPB leadership:
Conduct organization design and workforce strategy development.
Design and implement a payroll and hiring system.
Pursue transfer agreements with other federal agencies currently performing consumer protection functions.
Staff up the bureau’s critical leadership positions and core functions.
2.2.3 Alignment with Performance Standards and Best Practices
We use OPM’s HCAAF framework to conduct a broad-based evaluation of the CFPB’s performance in the area of Human Capital and Organizational Development. Below, we describe the three dimensions or “systems” of HCAAF that are the focus of our evaluation, along with specific evaluation criteria for each. Each HCAAF system is based on critical success factors that make up the overall system. Critical success factors are the areas on which agencies and human capital practitioners should focus to achieve a system’s standard for success principles. Each critical success factor comprises key elements that can be examined to determine organizational development and human capital system maturity. These critical success factors, and the associated key elements, serve as evaluation criteria for our performance audit, within each HCAAF system. For a comprehensive list of critical success factors and key elements, please refer to Office of Personnel Management’s HCAFF Resource Center at the following link: http://www.opm.gov/hcaaf_resource_center/. Leadership and Knowledge Management System
The Leadership and Knowledge Management System focuses on identifying and addressing leadership competencies so that continuity of leadership is ensured, knowledge is shared across the
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
14
organization, and an environment of continuous learning is present. This system comprises five critical success factors and their key elements.
1. Leadership Succession Management
2. Change Management
3. Integrity and Inspiring Employee Commitment
4. Continuous Learning
5. Knowledge Management
Results-Oriented Performance Culture System
The Results-Oriented Performance Culture System focuses on having a diverse, results-oriented, high-performing, workforce, as well as a performance management system that effectively plans, monitors, develops, rates, and rewards employee performance. This system comprises six critical success factors and their key elements.
1. Communications
2. Performance Appraisal
3. Awards
4. Pay-for-Performance
5. Diversity Management
6. Labor/Management Relations
Talent Management System
The Talent Management System focuses on agencies having quality people with the appropriate competencies in mission-critical activities. This system comprises two critical success factors and their key elements.
1. Recruitment
2. Retention
2.3 Findings and Recommendations
In this section, we present key findings and recommendations for each of the three sets of criteria included in the performance audit: (1) compliance with the legal requirements; (2) achievement of organizational goals; and (3) alignment with performance standards, best practices, and/or benchmarks. The supporting tables referenced throughout this section are presented at the end of the section.
2.3.1 Compliance with Legal Requirements
Table 1 presents our assessment of the CFPB’s compliance with legal requirements. Each row in this table specifies a legal requirement for the CFPB. For each legal requirement, we describe the progress that the bureau has demonstrated to date, along with recommendations (as applicable) for future action. The section below highlights our key findings and recommendations:
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
15
CFPB fully complied with the requirement to develop a Recruitment and Retention Plan, Training and Workforce Development Plan and Workforce Flexibilities Plan. CFPB delivered these plans to Congress on July 21, 2011, as part of the report Developing our Human Capital. The document identifies achievements as well as near and longer term actions in each of the three requirement areas.
CFPB met the requirement of the Dodd-Frank Act to develop a compensation and benefits program. CFPB benchmarked the Federal Reserve Board and other FIRREA agencies to come up with a comparable and competitive compensation model to attract mission-critical and support occupations. Retirement and non-retirement benefits were benchmarked across government agencies to develop benefits and programs that are progressive and timely. Thorough analysis led to developing compensation models and a benefits package that goes beyond the limitations of Title V.
CFPB leveraged best practices in developing procedures for employee transfers. CFPB drew on information from the report Research & Analysis: Organizational Stand-ups Lessons Learned and Key Insights to guide the development of procedures for transferring employees from other agencies. Specifically, this report describes a case study of the Federal Housing Finance Agency (FHFA), which underscores the importance of understanding the legislative requirements for transfer employees. The FHFA encountered a significant roadblock in numerous OMB and OPM regulations on government employee transfers, and struggled with the maze of federal regulations while trying to achieve organizational goals. CFPB found that although negotiating MOUs with six transferring agencies was a lengthy process, the value of transferred employees from other federal agencies was significant. CFPB established a centralized recruitment and outreach process to identify, interview and select federal employees for its mission-critical Examiner and Consumer Response positions. This system helped CFPB to successfully attract and negotiate the transfer of highly-skilled employees from other Federal agencies between July and October 2011.
2.3.2 Achievement of Organizational Goals
Table 2 presents our assessment of the CFPB’s achievement of organizational goals. Each row in this table corresponds to a specific CFPB organizational goal. For each goal, we describe the progress that the bureau has demonstrated to date, along with recommendations for future action (as necessary). The section below highlights our key findings and recommendations for each goal.
CFPB established an organizational design and a workforce plan and approach. This goal was completed in the following ways: o CFPB developed a preliminary organizational design composed of six units, and an
overall targeted head count of 1325 employees. To accompany the organizational design each unit developed vision and functional statements.
o CFPB units were tasked to implement staffing and hiring actions such as determining the number and type of positions for each level. Position descriptions were developed for each position; vacancy announcements developed and job vacancies were advertised in USAJOB.
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
16
CFPB designed and implemented a payroll and hiring system. This goal was completed in the following ways: o In compliance with the Dodd-Frank Act requiring that CFPB’s compensation system be
comparable to that of the Federal Reserve Board, CFPB designed a compensation approach and model based on benchmark studies of the Federal Reserve Board compensation approach and model as well as other FIRREA agencies.
o Benefits packages were benchmarked from the same agencies and included both retirement and non-retirement benefits. The CFPB benefits package goes beyond the typical federal benefits package by offering benefits such as short- and long-term disability, dental and vision benefits, business travel accident insurance, and a flexible spending account.
o CFPB designed their hiring system by classifying jobs of most critical positions first, creating a job leveling system, including pay bands. The hiring system classified required positions, starting with the most critical positions.
o A major task in CFPB’s launch was to set up payroll and human resource transaction systems. The National Finance Center’s (NFC) payroll system and the Department of Treasury’s personnel system, HR Connect, were chosen and implemented. Many of the Dodd-Frank transfer agencies use the NFC finance system; thus, the use of this system by CFPB facilitated the employee transfer process to CFPB.
CFPB has transferred employees from other federal agencies to address mission-critical
staffing needs. CFPB identified the major mission-critical and supporting functional positions required, and negotiated with six federal agencies for positions to support mission-critical functions being transferred to CFPB. A memorandum of understanding (MOU) was developed that specifies the agreement with the federal agencies to transfer employees into CFPB. An ‘Expression of Interest’ was implemented with federal agencies, and interviewing and selection criteria were outlined in MOUs, resulting in 232 transferees into CFPB.
CFPB should staff up the bureau’s leadership positions and core functions. This goal is
mostly complete. To date, 4 of the 6 Associate Directors are on board and 20 of the 36 Assistant Directors are on board. Going forward, it is important to continue the search to fill needed leadership positions in a timely manner. The following activities were completed for this goal: o CFPB identified and detailed federal employees to serve on an implementation team
which carried out initial planning and execution of core functions and leadership needs. o The implementation team developed a hiring process by meeting with its members to
define competencies for Associate Directors. Associate Directors were hired and the same process was performed to define competencies for and to hire Assistant Directors. Assistant Directors defined competencies for mission critical positions such as Examiners, Research & Market Analysts, Economists, and Financial Analysts. Thus, the key mission-critical functions and supporting populations were hired into CFPB in a cascading fashion.
o Key hiring policies were implemented, such as policy number CFPB-COO-011 (Excepted Service Non-Executive Positions under Waiver Authority Interim Policy). This policy describes the methodology and authorities the CFPB will use to create, evaluate, and fill non-executive positions that are excepted from the competitive service, pursuant to the waiver provision in § 1013(a)(1)(C) of the Consumer Financial Protection Act of 2010.
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
17
o Going forward, it is important to continue the search for the balance of the Associate and Assistant Directors to fill needed leadership positions in a timely manner. Associate and Assistant Directors have an important role as leaders to set actions for their units to accomplish the short and long-term goals set for the CFPB as a new bureau with high visibility. This should be a priority search for CFPB and goals should be set for Assistant Directors to be hired within the first two quarters of the FY 2012 fiscal year.
2.3.3 Alignment with Performance Standards and Best Practices
Table 3, Table 4 and Table 5 present our assessment of the CFPB’s alignment with performance standards and best practices. Each row in these tables corresponds to a specific critical success factor within the corresponding HCAAF system. For each critical success factor, we provide the following information: (1) a rating of CFPB’s performance to date, using a stoplight scale (i.e., Red, Yellow or Green); (2) a summary of demonstrated performance; (3) the priority of future progress in this area, based on the importance of the performance area for a start-up organization; and (4) recommendations for future action. Table 6 presents high-level recommendations for the two HCAAF Systems (Strategic Alignment and Accountability) that are outside the scope of this audit. The section below highlights our key findings and recommendations—those that are the most critical at this time for the CFPB’s Human Capital Office. They are derived from the findings that are “High” priorities in the matrices on the following pages.
CFPB should develop a formal Human Capital Program Plan, which would build on existing projects and systems. The Human Capital Office is in a start-up mode and has multiple human capital systems that have been designed or are planned to be implemented in FY 2012. It is important for the Human Capital Office to formalize their various plans and projects by developing a Human Capital Program Plan (HCPP). The HCPP is a functional plan that will integrate the Human Capital Office vision and mission and strategic goals for CFPB. Use of the HCAAF standards set by OPM is a good framework to comply with legal and federal standards and also used as a guide. A formal plan should be developed in the near term and led/managed by the Chief Human Capital Officer (CHCO) or similar position in the Human Capital Office to oversee and make decisions about Human Capital projects within the HCPP. The objective of an HCPP will be to coordinate all major human capital systems, some of which are already in progress; some of which need an implementation strategy; and other systems are still in a formative stage. The systems that will be part of the HCPP include, but are not limited to:
o Human Capital Strategy and Implementation plan o Executive/Management Development Program and Succession Management system o Training and Workforce Development Program o Knowledge Management System o Performance Management System including a pay-for-performance and awards
programs o Cornerstone On-Demand system that facilitates implementation of the: performance
system, learning management system, knowledge management system, and integrated talent management system.
o Diversity Plan o Long-term Recruitment Plan
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
18
o Retention Plan
CFPB has followed best practices in organizational transformation through the creation of a “Culture Club”. A GAO report on Results-Oriented Cultures (GAO-03-669) highlights the importance of involving employees from the beginning in transformation efforts. CFPB has done just that with forming a Culture Club. The Culture Club has researched progressive approaches, held lunch and learns to communicate information; and completed surveys such as the Values survey and the Demographics and diversity survey. The GAO report states that creating opportunities for employees helps to accelerate the transformation and in CFPB’s case, establishing a work environment that provides ample communications, innovation and creativity. This is a unique opportunity for CFPB as a start up bureau to create an environment that is characterized by the values of open communications and shared responsibility for accomplishing organizational goals and objectives. While the Culture Club has had many accomplishments they need a formal charter establishing the Culture Club as an organization with a purpose and process to continue the energy, creativity, and activity establishing the work they will be doing in months and years to come. The Culture Club charter should consider the following:
o Set a Culture Club vision, case for change to establish raison d'être for the Culture
Club. This statement will explain the purpose and objectives for the group. o Gain executive sponsorship – who will be the sponsor and what is their role and
responsibility as leader/s? o Establish membership and representation from all CFPB units and expertise – who are
the members, how are they chosen, what are their responsibilities, how long is their tenure; do members rotate?
o Develop multiple outreach methods – lunch and learns are excellent forms of communicating and training on important topics there are additional methods to exchange ideas. Determine the various outreach methods and how outreach, communications, training can increase morale and bureau engagement.
o Uncover important information that is not spoken or shared in formal sessions. Identify methods for anonymous input to provide for broader representation of ideas and diversity of information.
o Develop a Culture Club project plan that is communicated to CFPB and seeks broad input.
CFPB should continue to implement its recruitment strategy. CFPB has done an excellent job at filling positions to stay on target with recruiting goals and should continue aggressive recruiting efforts through FY 2012 to hire the balance of personnel to staff CFPB at its targeted level. It is important that CFPB follow through by implementing its recruitment strategy, vision and goals stated in the September 23, 2011 presentation: CFPB Recruitment Strategy & Update. There are over 400 mission critical vacancies and a number of outreach activities that have been identified for FY 2012. This is a big effort for the CFPB Human Capital Office this year and one that can be accomplished by following through with the strategy and action plans to support the challenges that have been defined in the presentation. There are over 25 actions suggested. Some are complex efforts that coordinate detailed plans
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
19
and groups of personnel. Dedication, commitment, coordination and expertise will be needed at all levels to accomplish these actions. In the near term consider the following actions:
o Building the recruitment infrastructure of specialists and CFPB workforce will be significant to accomplishing the outreach efforts, plans and multiple actions.
o Identify a project manager to lead the effort and set clear expectations and accountabilities.
o Consider detailing CFPB staff into recruitment efforts on a rotational basis and provide a form of benefit for their contribution; possibly a letter for their file sent to their manager showing commitment and dedication.
o Evaluate results and update strategy, goals and plans to stay as much on track as possible.
CFPB should fully develop a Training and Workforce Development Plan. The Dodd-
Frank Act specifically calls for a Training and Workforce Development plan, and this continues to be a high priority and immediate need for CFPB. In the Annual Report to Congress on July 21, 2011, Developing our Human Capital, CFPB defined an approach to training and workforce development. To support their mission, CFPB has developed and held lunch and learns, on-boarding training, and approximately three weeks of training for the core Examiner and Consumer Response workforces. An assessment of workforce skills has been executed and core competencies for executives and non-executives have been developed. CFPB has a longer term goal to develop as a learning organization. In the near term, the Training and Workforce Development Plan should ensure that CFPB has a consistent and unified approach to training and workforce development, across all units and employee populations. Some near term activities to include in the Training and Workforce Development Plan:
o Apply competency models to develop career paths. o Identify a skills matrix for each family of positions and for each level. o Plan and implement the Emerging Leader or Executive Candidate Development
Program. o Plan and implement an Executive Management Development Program.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
20
Tab
le 1
: C
omp
lian
ce w
ith
Leg
al R
equ
irem
ents
Lega
l Req
uire
men
t De
mon
stra
ted
Perfo
rman
ce
Find
ing
/ Rec
omm
enda
tion
Sect
ion
1067
of t
he D
odd-
Fran
k Ac
t req
uire
s th
e bu
reau
to s
ubm
it an
annu
al
repo
rt to
the
Com
mitte
e on
Ban
king,
Hou
sing,
and
Urb
an A
ffairs
of t
he S
enat
e an
d th
e Co
mm
ittee
on F
inan
cial S
ervic
es o
f the
Hou
se o
f Rep
rese
ntat
ives
that
in
clude
s: (1
) a R
ecru
itmen
t and
Ret
entio
n Pl
an; (
2) a
Tra
inin
g an
d W
orkf
orce
De
velo
pmen
t Pla
n; a
nd (3
) a W
orkf
orce
Fle
xibilit
ies
Plan
.
Annu
al R
epor
t To
Cong
ress
, Jul
y 21
, 201
1: D
evel
opin
g ou
r Hu
man
Cap
ital--
•
Recr
uitm
ent a
nd R
eten
tion
Plan
•
Trai
ning
and
Wor
kfor
ce D
evel
opm
ent P
lan
• W
orkf
orce
Fle
xibilit
ies
Plan
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Sect
ion
1013
of t
he D
odd-
Fran
k Ac
t req
uire
s th
at, “
The
Dire
ctor
sha
ll at a
ll tim
es
prov
ide
com
pens
atio
n (in
cludi
ng b
enef
its) t
o ea
ch c
lass
of e
mpl
oyee
s th
at, a
t a
min
imum
, are
com
para
ble
to th
e co
mpe
nsat
ion
and
bene
fits th
en b
eing
pro
vided
by
the
Boar
d of
Gov
erno
rs fo
r the
cor
resp
ondi
ng c
lass
of e
mpl
oyee
s.”
Deve
lope
d an
d im
plem
ente
d co
mpe
nsat
ion
and
bene
fits
prog
ram
s th
at m
et th
e re
quire
men
t of t
he D
odd-
Fran
k Ac
t. No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce e
lem
ent
Purs
uant
to th
e Do
dd-F
rank
Act
, the
CFP
B ha
s co
llabo
rate
d wi
th th
e six
tra
nsfe
rring
age
ncie
s to
est
ablis
h pr
oced
ures
and
sys
tem
s th
at a
llow
for
empl
oyee
s tra
nsfe
rring
into
the
CFPB
to re
tain
app
ropr
iate
ben
efits
pro
vided
to
them
by
thei
r prio
r age
ncy
for a
one
-yea
r per
iod,
and
to re
imbu
rse
thos
e ag
encie
s as
requ
ired
by th
e Do
dd-F
rank
Act
. The
six
agen
cies
are:
the
Depa
rtmen
t of H
ousin
g an
d Ur
ban
Deve
lopm
ent,
Offic
e of
Thr
ift Su
perv
ision
, O
ffice
of th
e Co
mpt
rolle
r of t
he C
urre
ncy,
Nat
iona
l Cre
dit U
nion
Adm
inist
ratio
n,
Fede
ral D
epos
it Ins
uran
ce C
orpo
ratio
n, a
nd th
e Fe
dera
l Res
erve
Boa
rd o
f G
over
nors
and
Fed
eral
Res
erve
Sys
tem
Ban
ks.
Esta
blish
ed a
nd im
plem
ente
d a
cent
raliz
ed re
crui
tmen
t and
ou
treac
h pr
oces
s fo
r the
iden
tifica
tion,
recr
uitm
ent,
inte
rvie
wing
and
sel
ectio
n of
indi
vidua
ls. N
egot
iate
d an
d im
plem
ente
d m
emor
anda
of u
nder
stan
ding
(MO
Us) w
ith th
e De
partm
ent o
f Hou
sing
and
Urba
n De
velo
pmen
t, Fe
dera
l De
posit
Insu
ranc
e Co
rpor
atio
n, F
eder
al R
eser
ve S
yste
m,
Natio
nal C
redi
t Uni
on A
dmin
istra
tion,
Offic
e of
the
Com
ptro
ller
of th
e Cu
rrenc
y, a
nd th
e O
ffice
of T
hrift
Supe
rvisi
on, t
o tra
nsfe
r em
ploy
ees
to th
e CF
PB. M
OUs
inclu
de p
roce
sses
an
d pr
oced
ures
for m
anag
ing
trans
ferra
ble
bene
fits u
nder
the
Dodd
-Fra
nk A
ct.
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Unde
r the
Dod
d-Fr
ank
Act C
FPB
mus
t est
ablis
h bu
sines
s un
its in
the
area
s of
re
sear
ch, c
omm
unity
affa
irs a
nd c
olle
ctin
g an
d tra
ckin
g co
mpl
aint
s. T
he D
odd-
Fran
k Ac
t sta
tes
that
the
follo
wing
offic
es s
houl
d be
dev
elop
ed w
ithin
one
yea
r of
the
desig
natio
n tra
nsfe
r dat
e of
Jul
y 21
, 201
1 to
inclu
de, f
air l
endi
ng a
nd
enfo
rcem
ents
, fin
ancia
l edu
catio
n, s
ervic
emem
bers
affa
irs; a
nd w
ithin
180
day
s of
the
trans
fer d
ate,
offic
es s
uch
as, f
inan
cial p
rote
ctio
n fo
r old
er A
mer
icans
and
m
inor
ity a
nd w
omen
inclu
sion,
om
buds
man
, and
con
sum
er a
dviso
ry b
oard
sh
ould
be
esta
blish
ed.
Deve
lope
d an
d im
plem
ente
d a
work
forc
e pl
an a
nd
orga
niza
tiona
l stru
ctur
e th
at in
clude
s al
l the
units
and
offic
es
requ
ired
by th
e Do
dd-F
rank
Act
.
Hire
per
sonn
el to
dire
ct a
nd im
plem
ent
the
offic
es a
nd u
nits
func
tions
as
requ
ired
by th
e Do
dd-F
rank
Act
.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
21
Tab
le 2
: Ach
ieve
men
t of O
rgan
izat
iona
l Goa
ls
Org
aniz
atio
nal G
oals
De
mon
stra
ted
Perfo
rman
ce
Find
ing
/ Rec
omm
enda
tion
Cond
uct o
rgan
izatio
n de
sign
and
work
forc
e st
rate
gy d
evel
opm
ent.
• CF
PB d
evel
oped
a p
relim
inar
y or
gani
zatio
nal d
esig
n co
mpr
ised
of s
ix un
its.
• Ea
ch C
FPB
unit d
evel
oped
visi
on a
nd fu
nctio
nal s
tate
men
ts.
• CF
PB u
nits
wer
e ta
sked
to d
eter
min
e th
e nu
mbe
r and
type
of p
ositio
ns a
t eac
h le
vel; d
evel
op p
ositio
n de
scrip
tions
, vac
ancy
ann
ounc
emen
ts, jo
b va
canc
ies
to
adve
rtise
in U
SAJO
B.
• Id
entify
gap
s be
twee
n pr
ojec
ted
or a
ctua
l ava
ilabi
lity
of th
e CF
PB’s
miss
ion-
critic
al c
ompe
tenc
ies
and
the
curre
nt a
nd fu
ture
dem
ands
.
Desig
n an
d im
plem
ent a
pay
roll a
nd h
iring
syst
em.
• CF
PB d
esig
ned
a co
mpe
nsat
ion
appr
oach
and
ben
efits
pac
kage
s ba
sed
on
benc
hmar
ks fr
om F
eder
al R
eser
ve B
oard
and
oth
er F
IRRE
A ag
encie
s fo
r co
mpe
nsat
ion
mod
els
as id
entifi
ed in
Dod
d-Fr
ank
Act.
•
CFPB
des
igne
d th
eir h
iring
syst
em b
y cla
ssify
ing
jobs
of m
ost c
ritica
l pos
itions
first
, cr
eatin
g jo
b le
vels
by s
tarti
ng w
ith G
S Sc
hedu
le a
nd d
evel
opin
g a
CFPB
mod
el
with
Pay
Ban
ds.
• CF
PB re
alize
d th
at to
tran
sfer
em
ploy
ees
from
one
fede
ral a
genc
y to
CFP
B th
ey
need
ed to
set
up
a pa
yrol
l pro
vider
. The
Nat
iona
l Fin
ance
Cen
ter (
NFC)
and
pe
rson
nel s
yste
m, H
R Co
nnec
t, we
re c
hose
n.
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce
elem
ent
Purs
ue tr
ansf
er a
gree
men
ts w
ith o
ther
fe
dera
l age
ncie
s cu
rrent
ly pe
rform
ing
cons
umer
pro
tect
ion
func
tions
.
• CF
PB id
entifi
ed th
e m
ajor
miss
ion-
critic
al a
nd s
uppo
rting
func
tiona
l pos
itions
. •
CFPB
dev
elop
ed a
mem
oran
dum
of u
nder
stan
ding
to n
egot
iate
with
six
fede
ral
agen
cies
to tr
ansf
er e
mpl
oyee
s.
• Ag
reem
ents
with
five
fede
ral a
genc
ies
were
neg
otia
ted
and
the
proc
ess
for
trans
ferri
ng e
mpl
oyee
s wa
s es
tabl
ished
and
impl
emen
ted.
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce
elem
ent
Staf
f up
the
bure
au’s
critic
al le
ader
ship
po
sitio
ns a
nd c
ore
func
tions
.
• CF
PB id
entifi
ed a
nd d
etai
led
fede
ral e
mpl
oyee
s to
ser
ve o
n an
impl
emen
tatio
n te
am to
hel
p st
and-
up C
FPB.
•
The
impl
emen
tatio
n te
am d
evel
oped
a h
iring
proc
ess.
The
y m
et w
ith O
rgan
izatio
n O
fficer
s to
def
ine
com
pete
ncie
s fo
r Ass
ocia
te D
irect
ors.
Ass
ocia
te D
irect
ors
were
hi
red
and
the
sam
e pr
oces
s wa
s pe
rform
ed to
def
ine
com
pete
ncie
s fo
r Ass
istan
t Di
rect
ors.
•
Assis
tant
Dire
ctor
s de
fined
com
pete
ncie
s fo
r miss
ion-
critic
al a
nd s
uppo
rting
po
pula
tions
for h
iring
core
func
tions
.
• St
aff
the
vaca
nt c
ritica
l lead
ersh
ip p
ositio
ns
• De
velo
p a
long
-term
recr
uitm
ent p
lan.
•
Long
-term
recr
uitin
g ef
forts
to fo
cus
on a
cqui
ring
spec
ializ
ed c
ompe
tenc
ies
nece
ssar
y to
roun
d ou
t wo
rkfo
rce
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
22
Tab
le 3
: Alig
nmen
t wit
h P
erfo
rman
ce S
tand
ards
(Lea
ders
hip
and
Kno
wle
dge
Man
agem
ent S
yste
m)
Fact
or
Scor
e Su
mm
ary
of P
erfo
rman
ce
Prio
rity
Find
ing
/ Rec
omm
enda
tion
Lead
ersh
ip
Succ
essio
n M
anag
emen
t
Key
acco
mpl
ishm
ents
inclu
de: (
1) D
esig
ned
and
appl
ied
the
Succ
essio
n M
anag
emen
t App
arat
us to
cap
ture
dat
a of
lead
ersh
ip
work
forc
e, p
roje
ctio
n of
attr
ition
for t
erm
app
oint
men
ts;(2
) Use
d th
e Ex
ecut
ive C
ore
Qua
lifica
tions
(ECQ
s) a
s a
basis
for d
evel
opin
g CF
PB E
xecu
tive
Com
pete
ncie
s; (3
) Ass
esse
d an
d pu
rcha
sed
succ
essio
n m
odul
e in
per
form
ance
tool
.
Low
De
velo
p Ex
ecut
ive/M
anag
emen
t Dev
elop
men
t Pro
gram
.
En
sure
ava
ilabi
lity o
f tra
ined
men
tors
to s
uppo
rt ne
w an
d pr
ospe
ctive
lead
ers;
and
em
ploy
ees
in d
evel
opm
ent p
rogr
ams.
Chan
ge
Man
agem
ent
Key
acco
mpl
ishm
ents
inclu
de: (
1) C
ultu
re c
lub
esta
blish
ed to
co
ordi
nate
and
pre
sent
lunc
h an
d le
arns
to c
omm
unica
te c
hang
e,
bran
ding
, eng
age
empl
oyee
s; (2
) Com
plet
ed a
dem
ogra
phics
an
alys
is to
def
ine
CFPB
dem
ogra
phics
and
dive
rsity
. (3)
Des
igne
d an
d im
plem
ente
d va
lues
and
cul
ture
wor
kpla
ce a
ctivi
ties.
High
De
fine
indi
vidua
l per
form
ance
pla
ns to
rate
lead
ers
and
man
ager
s on
thei
r im
plem
enta
tion
of c
hang
e in
itiativ
es a
s ch
ange
is o
ngoi
ng.
Do
cum
ent t
he b
urea
u’s
stra
tegy
and
pla
n fo
r com
mun
icatio
n of
ch
ange
.
Inte
grity
and
Insp
iring
Empl
oyee
Co
mm
itmen
t
Key
acco
mpl
ishm
ents
inclu
de: (
1) F
ocus
ed o
n op
en
com
mun
icatio
n by
hol
ding
mul
tiple
town
mee
tings
and
lunc
h an
d le
arns
; (2)
Com
plet
ed a
val
ues
surv
ey to
est
ablis
h co
re v
alue
s; (3
) Ne
w em
ploy
ees
atte
nd 1
.25
hour
s et
hics
trai
ning
.
Med
ium
Pa
rticip
ate
in a
n O
PM le
d, E
mpl
oyee
Vie
wpoi
nt S
urve
y to
utili
ze
a m
echa
nism
for a
nony
mou
s em
ploy
ee fe
edba
ck.
Es
tabl
ish ID
Ps in
cludi
ng te
amwo
rk, c
olla
bora
tion
and
othe
r m
echa
nism
s to
driv
e pe
rform
ance
for a
hig
hly
enga
ged
staf
f.
Cont
inuo
us L
earn
ing
Key
acco
mpl
ishm
ents
inclu
de: (
1) N
ew h
ire o
n-bo
ardi
ng p
rogr
am
esta
blish
ed u
nder
stan
ding
of h
ow to
bes
t eng
age
and
succ
eed
at
CFPB
(2) E
stab
lishe
d tra
inin
g fo
r miss
ion-
critic
al p
ositio
ns,
Exam
iner
s an
d Co
nsum
er R
espo
nse
Spec
ialis
ts; (
3) P
artn
ered
wi
th T
reas
ury
Dep
artm
ent t
o us
e th
e Tr
easu
ry L
earn
ing
Man
agem
ent S
yste
m.
High
De
velo
p CF
PB T
rain
ing
and
Wor
kfor
ce D
evel
opm
ent P
lan
that
bu
ilds
com
pete
ncie
s im
porta
nt to
stra
tegi
c go
als
and
obje
ctive
s an
d CF
PB’s
perfo
rman
ce p
lan
exec
utio
n.
Ti
e co
mpe
tenc
y m
odel
s to
indi
vidua
l dev
elop
men
t pla
ns fo
r m
issio
n cr
itical
em
ploy
ees.
Know
ledg
e M
anag
emen
t
Key
acco
mpl
ishm
ents
inclu
de: (
1) D
evel
oped
Sha
rePo
int s
yste
m
for l
ibra
ry o
f mat
eria
ls; (2
) Des
igne
d kn
owle
dge
man
agem
ent
syst
em e
nhan
cem
ents
for u
pcom
ing
perfo
rman
ce m
anag
emen
t to
ol; (
3) S
taff
parti
cipat
es in
con
fere
nces
and
com
mun
ities
such
as
in th
e re
sear
ch m
arke
ts a
nd re
gula
tions
and
Con
sum
er B
ehav
ior.
Med
ium
De
fine
the
valu
e of
sha
ring
know
ledg
e fo
r reu
se a
nd
colla
bora
tion.
Es
tabl
ish m
echa
nism
s su
ch a
s in
cent
ives
or a
requ
irem
ent o
n in
divid
ual p
erfo
rman
ce p
lans
to d
rive
use
and
reus
e da
ta
sour
ces.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
23
Tab
le 4
: A
lign
men
t w
ith
Per
form
ance
Sta
nd
ard
s (R
esu
lts-
Ori
ente
d P
erfo
rman
ce C
ult
ure
Sys
tem
)
Fact
or
Scor
e Su
mm
ary
of P
erfo
rman
ce
Prio
rity
Find
ing
/ Rec
omm
enda
tion
Com
mun
icatio
ns
Key
acco
mpl
ishm
ents
inclu
de: (
1) C
FPB’
s m
issio
n, g
oals
and
obje
ctive
s ar
e co
mm
unica
ted
in o
n-bo
ardi
ng a
nd m
ultip
le p
rogr
ams
and
com
mun
icatio
ns a
nd d
istrib
uted
in h
ard
copy
; (2)
Cul
ture
Clu
b ga
ther
s fe
edba
ck a
nd o
ther
inpu
t.
High
Es
tabl
ish a
com
mun
icatio
n st
rate
gy th
at s
hare
s th
e vis
ion,
m
issio
n, a
nd o
ther
rela
ted
docu
men
ts s
uch
as th
e Hu
man
Ca
pita
l Stra
tegi
c pl
an.
Su
rvey
em
ploy
ees
to g
athe
r dat
a th
at in
dica
tes
they
are
awa
re
of th
e st
rate
gic
plan
and
goa
ls.
Perfo
rman
ce
Appr
aisa
l
Key
acco
mpl
ishm
ents
inclu
de: (
1) D
esig
ned
com
pete
ncie
s at
all
leve
ls an
d de
velo
ped
a ra
ting
scal
e an
d co
mpe
tenc
y in
dica
tors
. (2)
De
signe
d pe
rform
ance
man
agem
ent s
yste
m fo
r im
plem
enta
tion
into
Cor
ners
tone
tool
. (3)
Fee
dbac
k “c
onve
rsat
ions
” in
lieu
of
perfo
rman
ce s
yste
m b
eing
hel
d fo
r all e
mpl
oyee
s re
gard
less
of
leng
th o
f em
ploy
men
t.
Med
ium
Es
tabl
ish d
ivisio
n go
als
that
tie to
org
aniza
tiona
l goa
ls.
In
tegr
ate
orga
niza
tion
goal
s in
to C
orne
rsto
ne p
erfo
rman
ce
man
agem
ent s
yste
m.
De
velo
p pr
oces
s fo
r dea
ling
with
poo
r per
form
ance
and
co
mm
unica
te p
roce
ss.
Awar
ds
Key
acco
mpl
ishm
ents
inclu
de: (
1) B
enef
its a
nd p
ay is
def
ined
in
on-b
oard
ing;
(2) C
ondu
cted
bes
t pra
ctice
rese
arch
foun
d in
sim
ilar
FIRR
EA a
genc
ies.
(3) P
rese
nted
cer
tifica
te o
f ach
ieve
men
t awa
rds
to th
e im
plem
enta
tion
team
and
the
Foun
der’s
Clu
b.
Low
De
sign,
com
mun
icate
and
impl
emen
t a fo
rmal
awa
rd p
rogr
am
that
alig
ns w
ith o
rgan
izatio
nal g
oals
and
valu
es.
Es
tabl
ish p
ropo
sed
awar
ds s
uch
as M
erit p
ay, S
hort-
term
in
cent
ives,
reco
gnitio
n pr
ogra
m a
nd o
ther
per
form
ance
awa
rd
prog
ram
s.
Pay
for P
erfo
rman
ce
Key
acco
mpl
ishm
ents
inclu
de: (
1) C
ompe
nsat
ion
met
hodo
logy
and
cr
eativ
e pa
y st
ruct
ures
hav
e be
en d
evel
oped
, exp
lain
ed a
nd
com
mun
icate
d br
oadl
y; (2
) Und
er th
e Do
dd-F
rank
Act
, est
ablis
hed
com
pens
atio
n an
d be
nefits
pro
gram
.
Med
ium
Es
tabl
ish c
lear
pay
dist
inct
ions
for p
erfo
rman
ce in
Cor
ners
tone
Pe
rform
ance
Man
agem
ent S
yste
m.
Co
mm
unica
te u
pdat
es, r
evisi
ons
and
perfo
rman
ce p
hilo
soph
y th
at c
reat
e in
cent
ives.
Dive
rsity
M
anag
emen
t
Key
acco
mpl
ishm
ents
inclu
de: (
1) D
evel
oped
and
pre
sent
ed C
FPB
Dem
ogra
phics
' Ana
lysis
to tr
ack
and
anal
yze
work
forc
e di
vers
ity.
(2) P
lan
for t
arge
ted
recr
uitin
g &
outre
ach
at d
ivers
ity-fo
cuse
d ev
ents
.
Med
ium
De
velo
p Di
vers
ity P
lan
and
com
mun
icatio
n th
roug
hout
CFP
B.
Pu
blish
up-
to-d
ate
polic
ies
that
indi
cate
zer
o to
lera
nce
for s
exua
l ha
rass
men
t and
disc
rimin
atio
n in
the
work
plac
e.
Labo
r Rel
atio
ns
Man
agem
ent
Key
acco
mpl
ishm
ents
inclu
de: (
1) T
he C
FPB
does
not
hav
e un
ion
activ
ity a
t thi
s tim
e, b
ut it
has
inve
sted
in s
taff
that
can
sup
port
labo
r re
latio
ns s
houl
d th
e oc
casio
n ar
ise.
N/A
Th
is is
not a
pplic
able
at t
his
time.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
24
Tab
le 5
: A
lign
men
t w
ith
Per
form
ance
Sta
nd
ard
s (T
alen
t M
anag
emen
t S
yste
m)
Fact
or
Scor
e Su
mm
ary
of P
erfo
rman
ce
Prio
rity
Find
ing
/ Rec
omm
enda
tion
Recr
uitm
ent
Key
acco
mpl
ishm
ents
inclu
de: (
1) R
ecru
ited
and
hire
d 52
5 em
ploy
ees
by 7
/31/
11 e
xcee
ding
fede
ral g
over
nmen
t tim
elin
es; (
2)
Esta
blish
ed re
crui
tmen
t pro
cess
in p
rivat
e an
d pu
blic
sect
ors
and
nego
tiate
d an
d im
plem
ente
d m
emor
anda
of u
nder
stan
ding
with
6
gove
rnm
ent a
genc
ies
to tr
ansf
er e
mpl
oyee
s to
the
CFPB
bet
ween
Ju
ly an
d O
ctob
er 2
011;
(3) D
evel
oped
a c
ompr
ehen
sive
set o
f m
etric
s to
mea
sure
hirin
g ef
fect
ivene
ss. (
4) C
ondu
cted
targ
eted
re
crui
tmen
t and
out
reac
h to
dive
rsity
sou
rces
and
sta
keho
lder
s.
High
De
velo
p lo
ng-te
rm R
ecru
itmen
t Pla
n to
: add
ress
sta
ffing
need
s an
d an
ticip
ated
gap
s in
crit
ical s
kills
and
com
pete
ncie
s; a
nd
esta
blish
per
form
ance
indi
cato
rs a
nd to
clo
se s
kill g
aps
for
miss
ion-
critic
al o
ccup
atio
ns.
De
velo
p in
nova
tive
hirin
g an
d ou
treac
h pr
ogra
ms
to a
ttrac
t ta
lent
ed a
nd s
kille
d ca
ndid
ates
from
dive
rse
back
grou
nds.
De
velo
p a
proc
ess
that
hol
ds m
anag
ers
acco
unta
ble
for
effe
ctive
and
effic
ient
recr
uitm
ent a
ctivi
ties
for t
heir
units
.
Rete
ntio
n
Key
acco
mpl
ishm
ents
inclu
de: (
1) C
FPB
has
esta
blish
ed
prod
uctiv
e, s
uppo
rtive
wor
k en
viron
men
t pro
gram
s su
ch a
s, fle
xible
wo
rk s
ched
ules
, tel
ewor
k, d
omes
tic p
artn
er b
enef
its, s
hort-
and
lo
ng-te
rm d
isabi
lity, e
mer
genc
y ch
ild c
are
serv
ices,
phy
sical
exa
m
prog
ram
, em
ploy
ee a
ssist
ance
pro
gram
and
par
enta
l leav
e be
nefits
; (2)
Tra
inin
g ha
s be
en d
evel
oped
for m
issio
n-cr
itical
oc
cupa
tions
; (3)
Inno
vativ
e co
mpe
nsat
ion
stra
tegi
es h
ave
been
de
velo
ped.
Med
ium
Expl
ore
stra
tegi
es to
reta
in m
issio
n-cr
itical
occ
upat
ions
.
De
velo
p a
rete
ntio
n pl
an.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
25
Tab
le 6
: R
ecom
men
dat
ion
s fo
r O
ut-
of-S
cop
e H
CA
AF
Sys
tem
s
HCAA
F Sy
stem
Re
com
men
datio
ns
Stra
tegi
c Al
ignm
ent S
yste
m
De
velo
p Hu
man
Cap
ital S
trate
gy th
at a
ligns
to th
e CF
PB’s
miss
ion,
goa
ls an
d ob
ject
ives
and
facil
itate
s wo
rkfo
rce
plan
ning
.
Es
tabl
ish a
stra
tegi
c pa
rtner
ship
with
Hum
an R
esou
rce
for w
orkf
orce
pla
nnin
g.
De
velo
p a
proc
ess
to c
olla
bora
te w
ith o
ther
fede
ral g
over
nmen
t age
ncie
s an
d pr
ivate
sec
tor r
egar
ding
effe
ctive
hum
an c
apita
l stra
tegi
es
and
to b
ench
mar
k be
st p
ract
ices
and
less
ons
lear
ned.
Acco
unta
bility
Sys
tem
De
velo
p a
form
al a
ccou
ntab
ility
syst
em th
at s
tate
s th
e bu
reau
’s ac
coun
tabi
lity p
olicy
, key
resp
onsib
ilitie
s, o
utco
mes
and
mea
sure
s,
mile
ston
es a
nd re
sults
and
mee
ts O
PM’s
requ
irem
ents
for a
sou
nd h
uman
cap
ital a
ccou
ntab
ility
syst
em th
at m
easu
res
effe
ctive
ness
in
mee
ting
the
requ
irem
ents
.
De
velo
p an
app
raisa
l sys
tem
for s
enio
r exe
cutiv
es th
at h
as a
ppro
pria
te m
easu
res
or in
dica
tors
of e
mpl
oyee
and
or c
usto
mer
feed
back
.
De
velo
p a
proc
ess
that
hol
ds m
anag
ers
and
hum
an re
sour
ces
offic
ers
acco
unta
ble
for e
fficie
nt a
nd e
ffect
ive h
uman
reso
urce
s m
anag
emen
t in s
uppo
rt of
the
bure
au’s
miss
ion.
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
27
Section 3: Consumer Response
3.1 Scope of Audit
In this section, we establish scope boundaries for our audit of CFPB’s performance in the area of Consumer Response. Consumer Response’s mandate is to facilitate the centralized collection of, monitoring of, and response to complaints regarding consumer financial products or services; and to interpret and utilize consumer complaints and other feedback both to improve its own operations and to contribute to the eventual improvement of consumer financial products/services. This mandate and the operations required to address it align closely with customer experience management and customer loyalty disciplines in a wide variety of business-to-business (B2B) and business-to-consumer (B2C) industries. In order to evaluate the CFPB’s performance with respect to Consumer Response, we employed an overall framework informed by both general customer experience management best practices and a behavioral model originally developed by the American Customer Satisfaction Index (ACSI) to provide insight into consumer satisfaction with local and federal government services (i.e., the American Consumer Satisfaction IndexTM Government Model)1. The resulting framework, diagrammed in the figure below, contains three main components—experience preparation, experience execution, and desired stakeholder behaviors. Our premise is that stakeholder2 behaviors and reactions with regard to a given entity (e.g., CFPB Consumer Response) are a direct byproduct of how well that entity: (1) understands stakeholder needs and expectations; (2) defines how it will address stakeholder needs and expectations; and (3) executes/adjusts its operational plans based on stakeholder feedback. Specifically, experience preparation may include key activities like:
defining and segmenting key operational stakeholders – consumers and/or others gathering insight from stakeholders on their needs and expectations relative to Consumer
Response activity – essentially, the “ideal experience” they desire crafting a high-level strategy to address stakeholder needs and deliver the desired stakeholder
experience, given any other pre-existing operational metrics or constraints (legal, operational or financial)
1 The American Customer Satisfaction Index, (ACSI) is a private company originally founded in 1994 through the partnership of the University of Michigan/Ross School of Business, the American Society for Quality, and Claes Fornell International. The ACSI interviews about 80,000 Americans annually and asks about their satisfaction with the goods and services they have consumed. Respondents address a wide range of business-to-consumer products and services, including durable goods, services, non-durable goods, local government services, federal government services, etc. Results from data collection and analyses are released to the public throughout each calendar year and utilized to inform and test behavioral models that connect product/service provider actions with desired customer outcomes (e.g., satisfaction, willingness to purchase and/or recommend). The American Consumer Satisfaction Index TM Government Model is one of these models.
2 The term “stakeholders” is used here to refer to consumers, Congress, covered persons/entities as defined in Dodd-Frank, and other federal agencies
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
28
defining clear roles, responsibility and accountability for ideal experience delivery within Consumer Response and between Consumer Response personnel and other relevant departments or agencies
Experience execution is all about following through: embedding key elements of ideal experience strategy and regular stakeholder feedback into daily operating processes, policies, and systems. Execution begins with implementing key business processes that reflect stakeholder needs; within Consumer Response, these would include intake, tracking/resolution and analysis/reporting processes. Beyond this, successful experience execution may be dependent on multiple related factors, including things like:
providing clarity to stakeholders around key business processes [Process Information] administering communication channels for stakeholders that reflect how stakeholders want to
interact with Consumer Response, available when stakeholders want them [Customer Service, Website]
instituting process and outcome measurement capabilities and using insight from measurement for the purposes of continuous improvement [Outcomes Measurement & Continuous Improvement]
Consumer Response Evaluation Framework
In the case of CFPB Consumer Response, resulting desired stakeholder behaviors may include things like:
stakeholder agreement that the bureau is delivering on its legislative mandate, stakeholder willingness to recommend existing CFPB Consumer Response processes to
others to resolve relevant disputes or address relevant inquiries,
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
29
stakeholder confidence in CFPB Consumer Response processes and personnel, or stakeholder cooperation, co-development and/or compliance with CFPB policies, processes
and guidance The CFPB’s Consumer Response function is new enough that it may not be possible to assess the degree to which the bureau is achieving these desired stakeholder behaviors today. However, we can examine its experience preparation and experience execution activities to date—as well as related systems, processes and tools—to gain insight on how well Consumer Response may achieve desired stakeholder behaviors in the future. For more information on each of the experience preparation and execution activity areas in the graphic above, see our evaluation criteria in Section 3.2. Our audit focuses predominantly on the CFPB credit card complaint system with the understanding that many of the tools, practices and roles being put into place to execute this system are foundational to future Consumer Response activities. That said, it is not expected that the activities and plans listed above will fully address all aspects of the performance framework listed in Section 3.1. Our efforts have disproportionately focused on those areas of experience preparation and execution that were fully operational as of August 31, 2011. In cases where the CFPB has already demonstrated progress or documented future-state plans, those activities are mapped to the corresponding area of our evaluation framework, and performance is evaluated relative to our proposed criteria (see Section 3.2). For those framework areas where the bureau has not yet demonstrated progress or has limited performance data, this performance audit provides general recommendations regarding: (1) best practices with respect to performance in these dimensions; and (2) future audits of performance in these areas. As an example, a detailed quantitative and qualitative analysis of call center operational efficiency is out of scope for this audit, although it represents a prospective focus area for future audits of Consumer Response performance given CFPB reliance on this as a complaint/inquiry intake channel.
3.2 Evaluation Criteria
The purpose of this section is to describe the evaluation criteria for this review area (associated findings and recommendations are presented in Section 3.3). As with other areas of performance, our audit focuses on three sets of criteria: (1) compliance with legal requirements; (2) achievement of organizational goals; and (3) alignment with performance standards, best practices, and/or benchmarks.
3.2.1 Compliance with the Law
The bullets below describe specific provisions of the Dodd-Frank Act that establish requirements and/or evaluation criteria in the area of Consumer Response (Sections 1013(b)(3) and 1034).
Section 1013(b)(3)(A) of the Dodd-Frank Act requires the CFPB to establish “a single, toll free telephone number, a website, and a database or utilizing an existing database to facilitate the centralized collection of, monitoring of, and response to consumer complaints regarding consumer financial products or services.”
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
30
Section 1013(b)(3)(A) of the Dodd-Frank Act requires the CFPB to coordinate with the FTC and other federal agencies to route complaints to those agencies, where appropriate, and route complaints “[t]o the extent practicable” to states that meet certain requirements.
Section 1013(b)(3)(C) of the Dodd-Frank Act requires the CFPB to report to Congress annually on complaint numbers, types and, where applicable, resolution. In addition, Section 1016(b)(2) calls for semiannual reports that include “an analysis of complaints about consumer financial products and services that the Bureau has received and collected in its central database on complaints during the preceding year.”
Section 1013(b)(3)(D) of the Dodd-Frank Act requires the CFPB to share data with prudential regulators, the Federal Trade Commission, other Federal agencies, and State agencies, to “facilitate preparation of [annual Congressional] reports . . . , supervision and enforcement activities, and monitoring of the market for consumer financial products and services.”
Section 1034(a) of the Dodd-Frank Act requires the CFPB to establish (in consultation with the appropriate federal regulators) “reasonable procedures to provide a timely response to consumers, in writing, where appropriate” to complaints and inquiries that include the regulators’ steps in response; responses received from the covered person; and any follow-up regulator actions.
Section 1013(e)(1)(B) of the Dodd-Frank Act requires the CFPB to monitor complaints by servicemembers and their families, and responses thereto.
3.2.2 Achievement of Organizational Goals
In order to assess achievement of organizational goals, we evaluated the progress that CFPB has made towards measurable goals that are documented in CFPB planning artifacts. The bullets below describe the specific organizational goals that are included in our analysis. These goals were derived from Consumer Response-provided documentation including new hire training materials, contact center statement of work and related service level agreement materials and product rollout schedules. Goals by major operational area include:
Overall Standup o Meet documented milestone timing in Contact Center Phase I & II milestone calendar o Meet documented milestone timing for overall Consumer Response project plan
(across all major initiatives, beyond just the CFPB contact center)
Intake of Consumer Contacts – Contact Center o 100% compliance with contact center service level agreement
Routing of (Credit Card) Complaints
o Routing of complaints to banks, regulators within 48 hours of intake
Routing of Other Contacts, Inquiries
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
31
o Immediate response to Tier 1 through 2 phone inquiries o Absolute maximum elapsed time of 7 days between warm transfer of Tier 3 phone
inquiry and resolution (ideal within 24 hours) o Acknowledgement of written inquiry within 48 hours of receipt o Response to written inquiry by Consumer Response within 30 days of receipt
Management and Tracking of Complaints and Resolution (Bank/Regulator Resolution)
o Response from bank/regulator to consumer within 10 days of initial complaint o Response from bank/regulator during 1st, 2nd or 3rd tier CFPB investigations (note:
target in this case is not yet established as of September 27, 2011)
Management and Tracking of Complaints and Resolution (CFPB Investigations) o Completion of 1st, 2nd or 3rd tier investigations within 20 days of investigation start
Quality Assurance and Analysis/Reporting of Contact Data
o To be determined, and therefore generally excluded from this “achievement of organizational goals” analysis; this element of Consumer Response operations is still clearly in standup mode (e.g., hiring analysts, investigation staff is in process as of September 27, 2011).
3.2.3 Alignment with Performance Standards and Best Practices
In order to assess alignment with performance standards and best practices, we evaluated the progress that CFPB has made relative to an overall performance framework that is informed by both general customer experience management best practices and the American Consumer Satisfaction IndexTM Government Model), as described in section 3.1. They include:
Planning Standards o Evidence of segmenting stakeholder base and soliciting information on desired
stakeholder experience (stakeholder experience definition) o Clear mapping between stakeholder experience and department functionality o Documentation that includes milestones, timing, critical dependencies
Governance Standards
o Clear roles/responsibilities/accountability within CR o Clear roles/responsibilities/accountability between CR and related agencies, covered
persons o Documented/clear/accessible internal operating standards and related targets
Measurement & Actioning Standards (Process)
o Ease and timeliness of intake processes o Ease and timeliness of resolution processes (credit cards) o Ease and timeliness of reporting processes (credit cards) o Alignment of channels/touch points to key consumer segments
Measurement & Actioning Standards (Information)
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
32
o Accessibility and transparency of complaint resolution process and outcomes (from stakeholder point of view)
Measurement & Actioning Standards (Customer Service) o Courtesy and professionalism of live touch points (800 # call center/IVR and live chat)
Measurement & Actioning Standards (Website)
o Ease/utility of CR website – consumer complaint intake form o Ease/utility of CR website – other current supporting functionality (e.g., Tell Your
Story)
Measurement & Actioning Standards (Outcomes) o Performance versus internal standards/metrics (e.g., time to resolution) o Performance versus stakeholder expectations (beyond basic compliance) o Linkage between measurement and continuous process improvement o Quality of reporting to inform future CFPB scope, reduce complaints over time
3.3 Findings and Recommendations
In this section, we present key findings and recommendations for each of the three sets of criteria included in the performance audit: (1) compliance with the legal requirements; (2) achievement of organizational goals; and (3) alignment with performance standards, best practices, and/or benchmarks. The supporting tables referenced throughout this section are presented at the end of the section.
3.3.1 Compliance with Legal Requirements
Table 7 presents our assessment of the CFPB’s compliance with legal requirements. Each row in this table corresponds to a specific legal requirement. For each requirement, we describe the progress that the bureau has demonstrated to date, along with recommendations for future action. The bullets below highlight our key findings and recommendations
CFPB’s Consumer Response function has complied with all relevant legal requirements. CFPB should use the credit card complaint standup approach – and learnings derived from its initial implementation – as a template of sorts as Consumer Response continues to expand its scope beyond the credit complaint area into mortgages and other financial products/services.
3.3.2 Achievement of Organizational Goals
Table 8 presents our detailed assessment of the CFPB’s achievement of organizational goals. Each row in this table corresponds to a specific organizational goal. For each goal, we describe the progress that the bureau has demonstrated to date (findings), along with recommendations for future action. The bullets below highlight our key findings and recommendations.
Consumer Response is in compliance with its own internal organizational performance targets in those areas where: (1) targets have been documented; and (2) CFPB has officially begun holding itself and others to performance targets that have been set thus far.
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
33
CFPB should finalize all remaining targets tied to major operational metrics – and begin
enforcing targets as soon as possible. As of this report, Consumer Response has yet to establish and/or enforce final targets for operational metrics like maximum bank/regulator response time during CFPB investigations, or standards around frequency and scope of periodic quality assurance analysis and reporting (outside the intake/call center area). The sooner CFPB establishes targets for these critical activity areas, the sooner it can begin tracking performance associated with the full scope of its mandate, and the better prepared it will be to provide periodic reporting and analysis to other stakeholders. From a practicality perspective, committing to and enforcing targets quickly also helps avoid generating an unworkable backlog of complaints and/or investigations as consumer contact volume invariably increases. Enforcing existing targets should also increase the speed with which key external contractors (e.g., contact center) build a sense of accountability and responsiveness to improve average customer service representative skills and consistency of service delivery.
CFPB should consider adding consumer resolution dispute rate to its featured short-list of major operational metrics. Including this metric (i.e., % of “resolved” complaints that consumers subsequently dispute) can increase leadership visibility into what affected consumers may perceive as the effectiveness of current Consumer Response processes, and help uncover themes and/or emerging issues in individual bank investigation performance. Today, all metrics and targets listed in section 3.2.2. of this document focus exclusively on efficiency (timeliness).
CFPB should organize milestone information across Consumer Response. We also suggest that Consumer Response establish a master milestone calendar across all its major projects and initiatives to track progress and surface critical interdependencies. Documentation provided by CFPB during this audit contains examples of master milestone tracking up through CFPB’s July 21 launch date, but only evidence of milestone development and tracking on an individual project and/or functional area basis thereafter. Consolidating and tracking milestones across projects today will continue to help the department manage its ongoing standup activities and communicate progress effectively to internal and external stakeholders.
CFPB should establish a single Consumer Response master dashboard to track and communicate actual performance against targets. This master dashboard may contain different tabs/views, covering either department-wide (standup) goals or goals specific to each financial product CFPB eventually addresses. Generally, however, the goal should be to minimize differences across dashboard views to ensure appropriate focus on the core elements of Consumer Response’s mission, and to facilitate easy comprehension and interpretation of performance data. We would, for example, expect the operational area categories from section 3.2.2 of this document (e.g., overall standup, intake of consumer contacts, routing of complaints) to remain fixed, across any covered/relevant financial product. Internal metrics from section 3.2.2 (e.g., compliance with contact center service level agreement) would also change very little across products, emphasizing process timeliness and consumer satisfaction data once CFPB emerges from its initial standup phase. Individual targets may vary more
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
34
broadly, reflecting process nuances associated with complaint resolution and investigation for different product types.
3.3.3 Alignment with Performance Standards and Best Practices
Table 9, Table 10 and Table 11 present our assessment of the CFPB’s alignment with performance standards and best practices. Each row in these tables corresponds to a specific performance criterion/success factor within our larger Consumer Response evaluation framework (see section 3.1). For each success factor, we provide the following information: (1) a rating of CFPB’s performance to date, using a stoplight scale (i.e., Red, Yellow or Green); (2) a summary of demonstrated performance; (3) the priority of future progress in this area, based on the importance of the performance area for a start-up organization; and (4) recommendations for future action. Two overarching themes exist across our evaluation, namely:
1. Consumer Response has clearly leveraged stakeholder feedback to help frame its initial organizational design. Recall that understanding stakeholder needs/expectations and using this understanding to inform operations is a critical driver of desired stakeholder behavior (e.g., adoption/usage, cooperation, recommendation).
2. Consumer Response currently demonstrates operational rigor to deliver the desired stakeholder experience from an intake process perspective – particularly when it comes to process documentation and training associated with its contact center.
Going forward, the challenge for Consumer Response is to:
Maximize consistency in its contact center intake technician and specialist performance; Develop the same process and performance rigor for currently developing operational areas
outside of intake, particularly in the areas of CFPB complaint review and investigation; Balance ongoing operational improvement in the credit card area while maintaining
momentum in the expansion of other covered financial products and services, and Continue to establish and use formal stakeholder feedback channels, both for continuous
improvement with its credit card complaint processes and to inform design as it moves beyond this area
The bullets below highlight our other key findings and recommendations not yet referenced in the preceding discussion within this document’s Findings and Recommendations section. Nearest-Term Opportunities for Improvement (High Priority)
CFPB should implement an OMB-approved consumer satisfaction survey as a basic means to begin systematically collecting feedback directly from those who are experiencing CFPB’s operations today.
CFPB should leverage the feedback it is already collecting. As one example, the bureau
should continue to establish operational goals and processes around mining contacts currently stored in Consumer Response’s contact management system as “feedback.”
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
35
CFPB should complete the standup of key remaining operational enablers. This includes launching Consumer Response’s consumer-facing knowledge base, completing implementation of its complex case management system, and ramping up to at least minimum analyst staffing levels required to support quality assurance reviews for CFPB investigations and to develop/execute a master performance dashboard (as referenced on page 31). It also includes accelerating the in-process standup of contact center CSR monitoring and coaching/training to improve consistency of CSR performance.
Mid-Term Opportunities for Improvement (Medium Priority)
CFPB should draft a more formal “stakeholder feedback platform” plan, which would address topics such as: (1) how feedback will be collected and used to improve operations; and (2) how feedback will be collected and used to improve financial products and services. CFPB should whiteboard current feedback mechanisms by key operational areas, (e.g., intake, routing, tracking/resolution, analysis) channels (e.g., website, toll-free number) and stakeholder type (e.g., prudential regulators, covered persons, consumer advocacy groups, mass consumer audiences). In order to test the relevance and value of these feedback mechanisms, CFPB should consider who will use the feedback from each data stream, how the feedback will be used, and what the bureau [or other relevant stakeholders] will do differently as a result of this feedback.
CFPB should look for gaps in the formality, frequency, coverage and intent/functionality of its existing feedback mechanisms. The ideal platform should include a mix of quick/near-time/operational feedback and broad/infrequent/strategic feedback. CFPB should bound the volume of feedback mechanisms in part based on its bandwidth to analyze the resulting data. Feedback channels can also offer the opportunity to understand CFPB performance/value from the view of the stakeholder and act as a form of outreach to collaborate on solution development or continuous improvement. One vehicle for this type of collaboration is a stakeholder advisory board/community (or multiple versions of the same). Tips to maximize the impact of stakeholder advisory boards include:
o Enact rotating membership, limiting stakeholder participants to 18 to 24-month terms maximum
o Focus formal board meetings/discussions on a single objective and related discussion topic whenever possible, and prepare board members with advance materials to provide context
o Use board member feedback to inform future topics and to shape the frequency of interaction – but generally, expect quarterly interaction at most
o Use a third-party facilitator to moderate meetings, allowing Consumer Response staff to contribute and listen actively. (Note: “third-party” can mean a CFPB staff member outside of Consumer Response. Focus group facilitation experience is a plus for any potential moderator.)
o Explore opportunities to facilitate interaction between board members outside Consumer Response – often, board members see the opportunity to build relationships with other members as part of what makes membership worthwhile
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
36
CFPB should communicate progress to key stakeholders. Specifically, the bureau should consider employing the concept of an “annual CFPB Consumer Response scorecard” to summarize key performance metrics, results, feedback themes and implications and/or anticipated improvement initiatives. A scorecard of this type, distributed to Consumer Response staff along with internal and external stakeholders, improves accountability, maximizes clarity of operations and reinforces CFPB’s commitment to its mandate.
CFPB should complement its existing position description and procedural documentation with RACI. A 1 or 2-page RACI document should map out who is responsible, accountable, who should be consulted and who should be informed with regard to major activities within Consumer Response. A RACI document provides a single, easily digestible artifact of roles and responsibilities with and across CFPB and related agencies/covered persons. This can be a valuable communications tool given how dependent Consumer Response operations are on close coordination with other CFPB offices and external stakeholders.
CFPB should institute a “universal contact code” policy for all contacts, assuming one does not currently exist. The bureau should mandate the use of this policy on all communications/status updates associated with individual complaints or related investigations – particularly on any documents that may exist outside of Consumer Response’s contact management system. The code can enable easy tracking of information as it flows between Consumer Response, regulators and covered persons, and should tie to relevant record ID codes within the contact management system.
Longer-Term Opportunities for Improvement (Low Priority)
CFPB should complete the conceptual development of a feedback platform, secure approvals as needed and begin to implement. Note that “approvals” in this case means both completing relevant compliance activity (e.g., Paperwork Reduction Act-mandated work), but also securing buy-in from other CFPB offices or other key stakeholders to utilize insight generated from the feedback that Consumer Response collects and analyzes.
CFPB should enhance process transparency to consumers and other stakeholders. One way to accomplish this goal is to leverage stakeholder feedback, in order to enhance the clarity of CFPB processes and performance expectations in ways that are relevant to each major stakeholder group. For consumers, one relatively quick “win” in this area would be to build notification capability to alert complainants as investigations move through CFPB’s tiers. For other CFPB offices, this could mean exploring the feasibility of replicating the current knowledge-sharing model in place with the Office of Servicemember Affairs (OSA), thereby improving the ability of other departments to contribute to Consumer Response’s investigation, tracking and analysis efforts.
CFPB should consider enhancing future intake specialist, investigator and QA/QC staff capabilities via certification program(s). It is our understanding that CFPB is in the process of developing more formal performance management systems as of this report date. Intake specialists, investigators and QA/QC staff are three CFPB operational roles that may benefit
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
37
from the establishment of a more formal certification program as part of this work. Setting and supporting certification expectations helps enforce consistent delivery of the desired stakeholder experience when it comes to complaint tracking, resolution and analysis – in much the same way as the formal customer service representative evaluation and training programs that Consumer Response is implementing now is designed to reinforce consistent quality among its contact center staff.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
38
Tab
le 7
: C
omp
lian
ce w
ith
Leg
al R
equ
irem
ents
Lega
l Req
uire
men
t De
mon
stra
ted
Perfo
rman
ce
Find
ing
/ Rec
omm
enda
tion
Cent
raliz
e th
e in
take
for c
onsu
mer
com
plai
nts
abou
t con
sum
er fin
ancia
l pr
oduc
ts a
nd s
ervic
es.
Esta
blish
“a s
ingl
e, to
ll-fre
e te
leph
one
num
ber,
a we
bsite
, and
a d
atab
ase
or u
tilizin
g an
exis
ting
data
base
to fa
cilita
te th
e ce
ntra
lized
col
lect
ion
of, m
onito
ring
of, a
nd re
spon
se to
con
sum
er
com
plai
nts
rega
rdin
g co
nsum
er fin
ancia
l pro
duct
s or
ser
vices
.” S
ectio
n 10
13(b
)(3)(A
).
• CF
PB w
ebsit
e •
Cont
act c
ente
r ope
ratio
nal
• Cr
itical
dep
ende
ncy
supp
ortin
g sy
stem
s (i.
e., C
RM)
oper
atio
nal a
t bas
e le
vel fu
nctio
nality
Mul
tiple
com
plia
nce
proo
f poi
nts
exta
nt to
day.
Rout
e co
mpl
aint
s. C
FPB
mus
t coo
rdin
ate
with
the
FTC
and
othe
r fe
dera
l age
ncie
s to
rout
e co
mpl
aint
s to
thos
e ag
encie
s, w
here
ap
prop
riate
, and
rout
e co
mpl
aint
s “[t
]o th
e ex
tent
pra
ctica
ble”
to s
tate
s th
at m
eet c
erta
in re
quire
men
ts.
Sect
ion
1013
(b)(3
)(A),
(B).
• Ro
utin
g po
lices
exe
cute
d via
con
tact
cen
ter a
nd
docu
men
ted
in C
onsu
mer
Res
pons
e St
anda
rd
Ope
ratin
g pr
oced
ures
– fo
cuse
d on
pru
dent
ial
regu
lato
rs, c
over
ed p
erso
ns.
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Re
port
to C
ongr
ess
annu
ally
on c
ompl
aint
num
bers
, typ
es
and,
whe
re a
pplic
able
, res
olut
ion.
Sec
tion
1013
(b)(3
)(C).
Se
mia
nnua
l rep
orts
will
requ
ire “a
n an
alys
is of
com
plai
nts
abou
t con
sum
er fin
ancia
l pro
duct
s an
d se
rvice
s th
at th
e CF
PB h
as re
ceive
d an
d co
llect
ed in
its c
entra
l dat
abas
e on
co
mpl
aint
s du
ring
the
prec
edin
g ye
ar.”
Sec
tion
1016
(b),
(c)(4
)
• No
repo
rting
due
as
of a
udit d
ate.
No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce e
lem
ent
Shar
e da
ta w
ith p
rude
ntia
l reg
ulat
ors,
the
Fede
ral T
rade
Com
miss
ion,
ot
her F
eder
al a
genc
ies,
and
Sta
te a
genc
ies,
to “f
acilit
ate
prep
arat
ion
of
[ann
ual C
ongr
essio
nal] r
epor
ts .
. . ,
supe
rvisi
on a
nd e
nfor
cem
ent
activ
ities,
and
mon
itorin
g of
the
mar
ket f
or c
onsu
mer
finan
cial p
rodu
cts
and
serv
ices.
” Se
ctio
n 10
13(b
)(3)(D
).
• No
repo
rting
due
as
of a
udit d
ate.
No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce e
lem
ent
Wor
k wi
th o
ther
regu
lato
rs to
est
ablis
h tim
ely
resp
onse
pro
cedu
res.
CF
PB s
hall e
stab
lish
(in c
onsu
ltatio
n wi
th th
e ap
prop
riate
fede
ral
regu
lato
rs) “
reas
onab
le p
roce
dure
s to
pro
vide
a tim
ely
resp
onse
to
cons
umer
s, in
writ
ing,
whe
re a
ppro
pria
te” t
o co
mpl
aint
s an
d in
quirie
s th
at in
clude
the
regu
lato
rs’ s
teps
in re
spon
se; r
espo
nses
rece
ived
from
th
e co
vere
d pe
rson
; and
any
follo
w-up
regu
lato
r act
ions
. Se
ctio
n 10
34(a
).
• Ro
utin
g po
lices
and
inve
stig
atio
n ex
pect
atio
ns
docu
men
ted
in C
onsu
mer
Res
pons
e St
anda
rd
Ope
ratin
g pr
oced
ures
Proc
esse
s wi
ll con
tinue
to c
hang
e ov
er n
ear-t
erm
as
CFP
B ite
rate
s wi
th re
gula
tors
and
cov
ered
pe
rson
s. E
xam
ple:
ban
k po
rtal a
djus
tmen
ts.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
39
Lega
l Req
uire
men
t De
mon
stra
ted
Perfo
rman
ce
Find
ing
/ Rec
omm
enda
tion
Mon
itor c
ompl
aint
s by
ser
vicem
embe
rs a
nd th
eir f
amilie
s, a
nd
resp
onse
s th
eret
o. S
ectio
n 10
13(e
)(1)(B
).
Co
ntac
t cen
ter p
aper
, web
, and
tele
phon
e co
mpl
aint
inta
ke m
etho
ds a
ll inc
lude
que
stio
ns to
id
entify
ser
vicem
embe
rs a
nd d
epen
dent
s of
se
rvice
mem
bers
as
well a
s br
anch
, ran
k, a
nd
stat
us.
Co
nsum
er R
espo
nse
perio
dica
lly s
hare
s ex
ports
of
serv
icem
embe
r com
plai
nts
with
OSA
.
OSA
's Co
nsum
er R
espo
nse
Spec
ialis
t atte
nded
Co
nsum
er R
espo
nse's
regu
lato
ry a
nd C
RM s
yste
m
train
ing
and
has
acce
ss to
the
CRM
sys
tem
, whi
ch
inclu
des
the
abilit
y to
que
ry b
y se
rvice
mem
ber.
• Di
rect
ion/
links
to V
A ho
me
loan
web
site
to a
cces
s sp
ecia
lized
ser
vices
out
side
curre
nt C
FPB
scop
e
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
40
Tab
le 8
: A
chie
vem
ent
of O
rgan
izat
ion
al G
oals
Ope
ratio
nal A
rea
Key
Inte
rnal
Met
ric/S
tand
ard
Targ
et W
hen
Fully
O
pera
tiona
l Ac
tual
To
Date
Fi
ndin
g / R
ecom
men
datio
n
Ove
rall S
tand
up
Cont
act C
ente
r Pha
se I
& II
mile
ston
e ca
lend
ar
Cons
umer
Res
pons
e Pr
ojec
t Pla
n
Mee
t doc
umen
ted
mile
ston
e tim
ing
Mee
t doc
umen
ted
mile
ston
e tim
ing
Phas
e I –
95%
don
e
Phas
e II
– 75
% d
one
Not y
et o
fficia
lly m
easu
red
Cons
umer
-facin
g FA
Q/k
nowl
edge
bas
e no
t onl
ine
Adva
nced
/com
plex
cas
e m
anag
emen
t sy
stem
not
com
plet
ely
in p
lace
Mas
ter p
roje
ct te
am lis
t and
mas
ter
cale
ndar
lead
ing
to la
unch
, bu
t no
ongo
ing
mas
ter m
ilest
one
cale
ndar
and
re
late
d tra
ckin
g ac
ross
team
s?
Inta
ke o
f Con
sum
er C
onta
cts
– Co
ntac
t Cen
ter
Cont
act C
ente
r Ser
vice
Leve
l Agr
eem
ent
100%
com
plia
nce
No
t yet
offic
ially
mea
sure
d SL
A in
revis
ion;
per
con
tract
or
agre
emen
t, do
es n
ot g
o in
to e
ffect
unt
il 90
day
s af
ter l
aunc
h da
te (7
/21)
.
That
sai
d, c
urre
nt C
RM d
ashb
oard
tra
ckin
g of
cal
l cen
ter s
ervic
e le
vels
all
“gre
en” f
or w
/o 9
/3/1
1
Rout
ing
of [C
redi
t Car
d]
Com
plai
nts
Com
plai
nt ro
utin
g to
ban
ks, r
egul
ator
s
With
in 4
8 ho
urs
With
in 4
8 ho
urs
No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce e
lem
ent
Rout
ing
of O
ther
Con
tact
s/
Inqu
iries
Re
spon
se to
pho
ne in
quiry
– T
ier 1
or 2
Resp
onse
to p
hone
inqu
iry –
Tie
r 3
Ackn
owle
dgem
ent o
f writ
ten
inqu
iry
Resp
onse
to w
ritte
n in
quiry
by
Cons
umer
Re
spon
se
Imm
edia
te
With
in 7
day
s m
axim
um (2
4 ho
urs
pref
erre
d)
With
in 4
8 ho
urs
With
in 3
0 da
ys
Not y
et o
fficia
lly m
easu
red
Targ
et o
f 85%
of p
hone
inqu
iries
addr
esse
d wi
thou
t tra
nsfe
r to
man
ager
or
CFP
B –
at 8
5.6%
w/o
9/3
CRM
das
hboa
rd e
xam
ples
sha
red
as o
f 9/
16 fo
cus
on v
olum
e vs
. “tim
elin
ess
of
resp
onse
”
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
41
Ope
ratio
nal A
rea
Key
Inte
rnal
Met
ric/S
tand
ard
Targ
et W
hen
Fully
O
pera
tiona
l Ac
tual
To
Date
Fi
ndin
g / R
ecom
men
datio
n
Mgt
./ Tr
ackin
g of
Com
plai
nts
& Re
solu
tion
Bank
/ Reg
ulat
or
Resp
onse
from
ban
k/re
gula
tor t
o co
nsum
er –
in
itial c
ompl
aint
Resp
onse
from
ban
k/re
gula
tor –
inqu
iries
tied
to
1st,
2nd,
3rd
tier i
nves
tigat
ion(
s)
With
in 1
0 da
ys
Not y
et e
stab
lishe
d
Not y
et o
fficia
lly m
easu
red
Not y
et o
fficia
lly m
easu
red
Not y
et h
oldi
ng b
anks
to 1
0-da
y ta
rget
.
No fo
rmal
targ
ets
set y
et.
Will
need
to s
et
clear
exp
ecta
tions
to m
eet t
arge
t for
tota
l el
apse
d in
vest
igat
ion
time
(see
nex
t row
).
CFPB
Rev
iew/
Inve
stig
atio
n
Elap
sed
time
– 1s
t, 2n
d, 3
rd tie
r inv
estig
atio
n W
ithin
20
days
of
inve
stig
atio
n st
art
Not y
et o
fficia
lly m
easu
red
Targ
et p
er n
ew h
ire tr
aini
ng.
CRM
func
tiona
lity th
at w
ill al
low
for e
laps
ed
time
track
ing
still
in d
evel
opm
ent.
QA
and
Ana
lysis/
Rep
ortin
g of
Co
ntac
t Dat
a
Still
in s
tand
up m
ode:
hirin
g an
alys
ts,
inve
stig
atio
n Q
A st
aff
Not y
et e
stab
lishe
d No
t yet
offic
ially
mea
sure
d Ca
ll cen
ter Q
A/Q
C in
frast
ruct
ure
well
deve
lope
d, a
lthou
gh S
LA m
onito
ring
and
anal
ysis
is ju
st b
egin
ning
.
Ope
n ar
ea is
inve
stig
atio
n an
alys
is an
d tra
ckin
g; e
xpec
t thi
s to
be
deve
lope
d in
pa
ralle
l with
cur
rent
CRM
/cas
e m
anag
emen
t sys
tem
dev
elop
men
t.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
42
Tab
le 9
: A
lign
men
t w
ith
Per
form
ance
Sta
nd
ard
s (P
lan
nin
g)
Fact
or
Scor
e Su
mm
ary
of P
erfo
rman
ce
Prio
rity
Find
ing
/ Rec
omm
enda
tion
Evid
ence
of
segm
entin
g st
akeh
olde
r bas
e an
d so
licitin
g in
form
atio
n on
des
ired
stak
ehol
der
expe
rienc
e (s
take
hold
er
expe
rienc
e de
finitio
n)
Mul
tiple
acc
ompl
ishm
ents
/pro
of p
oint
s, b
eyon
d th
ose
man
date
d (i.
e.,
SORN
pub
lic c
omm
enta
ry) i
nclu
ding
:
Co
nsum
er p
rimar
y re
sear
ch (I
DEO
)
In
vest
igat
ions
into
pee
r gro
up a
ctivi
ties
and
best
pra
ctice
s
Le
vera
ging
sec
onda
ry d
ata
(e.g
., IR
S ta
xpay
er p
refe
renc
e st
udy)
/exp
ertis
e
High
Bu
reau
sho
uld
keep
foun
datio
nal w
ork
in m
ind
when
rollin
g ou
t re
mai
ning
pro
duct
func
tiona
lity
Bu
reau
may
wan
t to
inve
st in
sup
plem
enta
l res
earc
h if/w
hen
CFPB
exp
lore
s ad
ditio
nal fu
nctio
nality
tied
to n
iche
cons
umer
se
gmen
ts (e
.g.,
elde
rly)
Clea
r map
ping
be
twee
n de
sired
st
akeh
olde
r ex
perie
nce
and
depa
rtmen
t fu
nctio
nality
Stak
ehol
der r
esea
rch/
inpu
t use
d fo
r web
site
desig
n, m
ulti-
chan
nel
cont
act a
ppro
ach,
and
inte
rnal
ope
ratin
g st
anda
rds/
met
rics
Med
ium
To
max
imize
tran
spar
ency
/cla
rity,
bur
eau
shou
ld c
onsid
er
prod
ucin
g m
appi
ng d
ocum
ent w
ith s
take
hold
er n
ame/
type
, key
su
gges
tion(
s), e
xistin
g re
late
d fu
nctio
nality
and
pla
nned
fu
nctio
nality
with
exp
ecte
d du
e da
tes.
o
Here
’s wh
at w
e he
ard
o
Here
’s wh
at w
e’ve
don
e
o
Here
’s wh
y
Docu
men
tatio
n th
at
inclu
des
mile
ston
es,
timin
g, c
ritica
l de
pend
encie
s
Ve
ry d
etai
led
docu
men
tatio
n ar
ound
con
tact
cen
ter i
tsel
f, bu
t hav
e ye
t to
see
over
arch
ing
Cons
umer
Res
pons
e fu
nctio
n m
aste
r pr
ojec
t pla
n –
in o
ne p
lace
/doc
umen
t
Im
porta
nt to
isol
ate
critic
al d
epen
denc
ies
and
cont
inge
ncy
plan
s
High
Bu
reau
sho
uld
crea
te s
ingl
e m
aste
r pro
ject
pla
n/ca
lend
ar if
it do
es n
ot e
xist t
oday
Bu
reau
sho
uld
clear
ly iso
late
crit
ical d
epen
denc
ies
asso
ciate
d wi
th s
aid
cale
ndar
/pla
n
Bu
reau
sho
uld
leve
rage
any
upc
omin
g st
rate
gic
plan
ning
/bud
getin
g ac
tivity
to b
olst
er p
lan
docu
men
tatio
n
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
43
Tab
le 1
0: A
lign
men
t w
ith
Per
form
ance
Sta
nd
ard
s (G
over
nan
ce)
Fact
or
Scor
e Su
mm
ary
of P
erfo
rman
ce
Prio
rity
Find
ing
/ Rec
omm
enda
tion
Clea
r rol
es /
resp
onsib
ilitie
s /
acco
unta
bility
with
in
CR
SO
Ps a
nd in
terv
iews
sug
gest
col
labo
ratio
n, c
omm
unica
tion
and
trans
pare
ncy
of ro
les/
resp
onsib
ilitie
s wi
thin
CR
– al
thou
gh ro
les
cont
inue
to e
volve
and
new
role
s em
erge
.
Ev
iden
ce o
f cle
ar ro
les
and
resp
onsib
ilitie
s wi
thin
CFP
B to
sup
port
CR J
uly
21 la
unch
dat
e (C
R St
eerin
g Co
mm
ittee)
.
SO
P sh
ows
evid
ence
of r
ole
expe
ctat
ions
with
rega
rd to
con
sum
er
cont
acts
, but
cla
rifyin
g an
d fo
rmal
izing
role
s –
in p
artic
ular
, via
ho
ldin
g ag
encie
s an
d co
vere
d pe
rson
s ac
coun
tabl
e fo
r the
m –
is a
wo
rk in
pro
gres
s
High
Bu
reau
sho
uld
inclu
de p
roce
ss m
easu
res
and
targ
ets
asso
ciate
d wi
th in
divid
ual r
oles
in p
ositio
n de
scrip
tions
/ pe
rform
ance
man
agem
ent e
xpec
tatio
ns; t
ie to
re
ward
s/re
cogn
ition
Clea
r rol
es /
resp
onsib
ilitie
s /
acco
unta
bility
be
twee
n CR
and
re
late
d ag
encie
s,
cove
red
pers
ons
Med
ium
Bu
reau
may
con
sider
form
al d
ivisio
n of
labo
r/RAC
I doc
umen
t as
syst
ems
norm
alize
– a
s sin
gle
go-to
arti
fact
of r
oles
, re
spon
sibilit
ies
with
in a
nd a
cros
s en
tities
for m
ajor
func
tions
If
CFPB
cho
oses
to c
reat
e a
form
al d
ivisio
n of
labo
r/RAC
I do
cum
ent,
it sho
uld
crea
te th
is co
llabo
rativ
ely
with
sta
keho
lder
s fo
r max
imum
impa
ct
Docu
men
ted/
clear
/ ac
cess
ible
inte
rnal
op
erat
ing
stan
dard
s an
d re
late
d ta
rget
s
In
tern
al s
tand
ards
and
targ
ets
set f
or m
ost o
pera
tiona
l are
as
Co
ntac
t cen
ter n
ew h
ire e
duca
tion
inclu
des
info
rmat
ion
on ta
rget
s
Ac
cess
ibilit
y an
d co
mm
on u
nder
stan
ding
of t
arge
ts a
cros
s en
tire
CR o
rgan
izatio
n an
d re
leva
nt e
xter
nal s
take
hold
ers
is un
clear
Ag
ain
– a
work
in p
rogr
ess
Med
ium
Bu
reau
sho
uld
expl
ore
linkin
g bo
th ta
rget
and
ratio
nale
with
in
staf
f tra
inin
g fo
r edu
catio
nal p
urpo
ses
Bu
reau
sho
uld
ensu
re th
at re
leva
nt m
etric
def
initio
ns a
re e
asily
ac
cess
ible
with
in a
ny fu
ture
das
hboa
rd re
porti
ng C
R ad
opts
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
44
Tab
le 1
1: A
lign
men
t w
ith
Per
form
ance
Sta
nd
ard
s (M
easu
rem
ent
& A
ctio
nin
g)
Fact
or
Scor
e Su
mm
ary
of P
erfo
rman
ce
Prio
rity
Find
ing
/ Rec
omm
enda
tion
PRO
CESS
: Eas
e an
d tim
elin
ess
of
inta
ke p
roce
sses
SO
P do
cum
ent w
ith c
lear
inta
ke p
roce
ss d
ocum
enta
tion
Tr
aini
ng m
odul
es c
ompl
ete
– ju
st o
ne e
xam
ple
of in
-dep
th C
SR
prep
arat
ion
to s
uppo
rt pr
oces
s
Ev
iden
ce o
f add
ress
ing
itera
tive
chan
ge re
ques
ts to
twea
k co
ntac
t ce
nter
SO
P/su
ppor
ting
CRM
High
Bu
reau
sho
uld
mon
itor u
ser c
omm
ents
for n
avig
atio
nal e
ase
past
initia
l inta
ke p
age
– co
nsid
er a
ddin
g to
web
site
func
tiona
lity
Bu
reau
sho
uld
impl
emen
t con
tact
cen
ter c
usto
mer
sat
isfac
tion
surv
ey a
s so
on a
s po
ssib
le
PRO
CESS
: Eas
e an
d tim
elin
ess
of
reso
lutio
n pr
oces
ses
(cre
dit c
ards
)
Ch
alle
nges
exp
erie
nced
in g
ettin
g su
pple
men
tal/fo
llow
up
inve
stig
atio
n da
ta fr
om b
anks
and
oth
er b
ank
porta
l func
tiona
lity
Ca
se m
anag
emen
t sys
tem
func
tiona
lity in
com
plet
e in
CRM
; de
velo
pmen
t wor
k un
derw
ay to
bui
ld o
ut fu
nctio
nality
Te
am-b
ased
inve
stig
atio
ns a
ppro
ach
min
imize
s le
arni
ng c
urve
for
new
staf
f
So
me
anec
dota
l pos
itive
feed
back
sha
red
by in
terv
iewe
es (f
rom
co
nsum
ers)
Med
ium
Bu
reau
sho
uld
impl
emen
t con
tact
cen
ter c
usto
mer
sat
isfac
tion
surv
ey a
s so
on a
s po
ssib
le
Bu
reau
sho
uld
cons
ider
em
ploy
ing
“uni
vers
al c
onta
ct c
ode”
to
enab
le e
asy
track
ing
of c
onta
cts
as in
form
atio
n flo
ws b
ack
and
forth
acr
oss
regu
lato
rs (a
nd to
incr
ease
abi
lity to
leve
rage
al
read
y el
ectro
nica
lly s
tore
d pa
perw
ork/
cont
act d
ata
asso
ciate
d wi
th in
divid
ual r
ecor
ds)
PRO
CESS
: Eas
e an
d tim
elin
ess
of
repo
rting
pro
cess
es
(cre
dit c
ards
)
Fo
rmal
repo
rting
(e.g
., Q
uality
Ass
uran
ce R
evie
ws) n
ot y
et
unde
rway
M
ediu
m
Bu
reau
sho
uld
cont
inue
with
rele
vant
QC
and
data
hire
s to
re
sour
ce m
easu
rem
ent,
insp
ectio
n, re
porti
ng a
nd re
late
d an
alys
is
PRO
CESS
: Al
ignm
ent o
f ch
anne
ls/to
uch
poin
ts to
key
co
nsum
er s
egm
ents
Clea
r con
nect
ion
betw
een
stak
ehol
der r
esea
rch
and
mul
ti-ch
anne
l ap
proa
ch
High
Bure
au s
houl
d co
ntin
ue to
min
e ch
anne
l usa
ge in
form
atio
n to
de
term
ine
whet
her n
eed
to a
djus
t hou
rs o
f ope
ratio
n/ac
cess
for
non-
inte
rnet
-bas
ed c
hann
els
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
45
Fact
or
Scor
e Su
mm
ary
of P
erfo
rman
ce
Prio
rity
Find
ing
/ Rec
omm
enda
tion
INFO
RMAT
ION:
Ac
cess
ibilit
y,
trans
pare
ncy
of
com
plai
nt re
solu
tion
proc
ess
and
outc
omes
- fro
m
stak
ehol
der p
oint
of
view
(PO
V)
No
form
al fe
edba
ck s
yste
ms
in p
lace
toda
y to
gat
her c
onsu
mer
re
actio
ns to
pro
cess
or o
utco
mes
– s
o di
fficul
t to
gaug
e
perfo
rman
ce fr
om s
take
hold
er P
OV
W
hile
exis
ting
inta
ke c
hann
els
allo
w fo
r uns
truct
ured
feed
back
(via
ph
one,
Tel
l You
r Sto
ry),
min
ing
of d
ata
to te
st
acce
ssib
ility/
trans
pare
ncy
is a
work
in p
rogr
ess
Ba
selin
e st
ill be
ing
mea
sure
d fo
r rel
ated
met
rics
like
cons
umer
re
solu
tion
disp
ute
rate
Low
Bu
reau
sho
uld
cont
inue
bui
ldin
g no
tifica
tions
cap
abilit
y/
cons
umer
por
tal a
cces
s to
allo
w fo
r mor
e ro
bust
sta
tus/
track
ing
capa
bility
(i.e
., no
tify c
onsu
mer
as
inve
stig
atio
n m
oves
thro
ugh
tiers
, as
rele
vant
).
CUST
OM
ER
SERV
ICE:
Cou
rtesy
an
d pr
ofes
siona
lism
of
live
touc
h po
ints
(8
00 #
cal
l cen
ter/I
VR
and
live
chat
)
Al
l CSR
s un
derg
o so
ft sk
ills tr
aini
ng to
rein
forc
e pr
ofes
siona
lism
in
addi
tion
to a
bro
ader
trai
ning
pro
gram
on
SOP
Ev
iden
ce o
f usin
g cu
rrent
CSR
feed
back
/cal
l per
form
ance
to
enha
nce
tool
s av
aila
ble
to C
SRs
durin
g co
nsum
er in
tera
ctio
n
Co
ntac
t cen
ter s
ervic
e le
vel a
gree
men
t set
s st
anda
rds
for C
SR
perfo
rman
ce, r
egul
ar s
corin
g/te
stin
g of
con
tact
s, a
nd th
e us
e of
re
late
d fin
ding
s to
impr
ove
train
ing
and
CSR
perfo
rman
ce;
howe
ver,
cont
ract
or n
ot o
fficia
lly h
eld
to S
LA u
ntil N
ovem
ber 1
In
itial o
ppor
tuni
stic
“test
” of li
ve c
hat a
nd 8
00#
show
ed c
ourte
ous,
pr
ofes
siona
l inte
ract
ion
but s
ome
coor
dina
tion
issue
s (i.
e.,
conf
lictin
g in
form
atio
n fro
m C
SR a
nd liv
e ch
at o
pera
tor o
n sa
me
topi
c)
Re
mot
e m
onito
ring
of 2
sam
ple
reco
rded
cal
ls al
so s
howe
d in
cons
isten
cy in
ser
vice
expe
rienc
e de
liver
y –
goin
g “o
ff sc
ript”
vers
us c
urre
nt S
OP,
for e
xam
ple
High
Bu
reau
sho
uld
acce
lera
te s
tand
up o
f cal
l cen
ter Q
C ac
tivity
and
re
late
d co
achi
ng/tr
aini
ng fo
r ind
ividu
al C
SRs
to im
prov
e co
nsist
ency
of c
onsu
mer
con
tact
exp
erie
nce
Bu
reau
sho
uld
expl
ore
pote
ntia
l to a
ccel
erat
e ad
optio
n of
SLA
to
befo
re N
ovem
ber 1
WEB
SITE
: Ea
se/u
tility
of C
R we
bsite
– c
onsu
mer
co
mpl
aint
inta
ke fo
rm
Web
site
Gra
der.c
om -
Web
site
eval
uatio
n to
ol to
eva
luat
e ea
se,
usab
ility
(in lie
u of
spe
cific
cons
umer
feed
back
)
W
ebsit
e G
rade
: 92
out o
f 100
. Rev
iew
repo
rt at
High
Bure
au s
houl
d m
onito
r use
r com
men
ts fo
r nav
igat
iona
l eas
e/ut
ility;
ca
n le
vera
ge lo
w co
st e
xistin
g to
ols
to g
et g
ener
al e
xper
ienc
e fe
edba
ck (e
.g.,
4Q)
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
46
Fact
or
Scor
e Su
mm
ary
of P
erfo
rman
ce
Prio
rity
Find
ing
/ Rec
omm
enda
tion
WEB
SITE
: Ea
se/u
tility
of C
R we
bsite
– o
ther
cu
rrent
sup
porti
ng
func
tiona
lity (e
.g.,
Tell
Your
Sto
ry)
http
://we
bsite
grad
er.c
om/s
ite/w
ww.c
onsu
mer
finan
ce.g
ov
High
Hom
epag
e
Bu
reau
sho
uld
cons
ider
mov
ing
“Bui
ldin
g th
e CF
PB” p
lace
men
t as
func
tiona
lity e
xpan
ds, t
o m
ake
room
for c
lear
cal
ls-to
-act
ion
asso
ciate
d wi
th c
ritica
l com
plai
nt in
take
act
ivity
Bu
reau
sho
uld
cons
ider
redu
cing
heig
ht o
f the
hom
epag
e to
m
inim
ize v
ertic
al s
crol
ling
Sear
ch E
ngin
e O
ptim
izat
ion
Bu
reau
sho
uld
cons
ider
mod
ifyin
g te
xt in
clude
d in
imag
es o
n th
e CF
PB h
omep
age;
imag
es c
anno
t be
read
by
sear
ch e
ngin
es
(Goo
gle,
Yah
oo, B
ing)
ther
efor
e, ra
nk lo
wer i
n se
arch
resu
lts
OUT
COM
ES:
Perfo
rman
ce v
ersu
s in
tern
al
stan
dard
s/m
etric
s (e
.g.,
time
to
reso
lutio
n)
M
any
inte
rnal
sta
ndar
ds n
ot y
et e
stab
lishe
d
Ho
weve
r, fo
r man
y of
thos
e se
t (e.
g., c
ompl
aint
rout
ing
to
bank
s/re
gula
tors
) com
plyin
g wi
th in
tern
al s
tand
ards
M
ediu
m
Bu
reau
sho
uld
cont
inue
impl
emen
tatio
n of
con
tact
cen
ter Q
A pl
an
Bu
reau
sho
uld
get n
on-c
onta
ct c
ente
r ope
ratio
ns to
sam
e le
vel
of m
etric
s vis
ibilit
y as
cal
l cen
ter:
This
may
inclu
de:
o
Crea
ting
auto
mat
ed d
ashb
oard
o
Mon
itorin
g no
less
than
3X
per m
onth
o
Ensu
ring
quar
terly
revie
w/an
alys
is cy
cle
o
Deve
lopi
ng im
prov
emen
t pro
cess
and
pla
ns fo
r met
rics
that
fall s
hort
of s
tand
ards
OUT
COM
ES:
Perfo
rman
ce v
ersu
s st
akeh
olde
r ex
pect
atio
ns (b
eyon
d ba
sic c
ompl
ianc
e)
No
cus
tom
er s
atisf
actio
n su
rvey
in p
lace
Aw
aitin
g sa
tisfa
ctio
n in
form
atio
n co
llect
ed v
ia o
ther
cha
nnel
s (e
.g.,
Tell Y
our S
tory
)
Pe
riodi
c m
eetin
gs w
ith o
ther
sta
keho
lder
s (i.
e., b
anks
, pru
dent
ial
regu
lato
rs)
Co
nsum
er R
espo
nse
Stee
ring
Com
mitte
e cr
eate
s fo
rmal
ity to
re
info
rce
coor
dina
tion
with
in C
FPB
No
form
al a
sses
smen
t yet
of p
erfo
rman
ce v
s. e
xpec
tatio
ns
Med
ium
Bu
reau
sho
uld
ram
p up
cus
tom
er s
atisf
actio
n su
rvey
pro
cess
as
soon
as
poss
ible
Bu
reau
sho
uld
cons
ider
em
ploy
ing
conc
ept o
f an
“ann
ual C
FPB
scor
ecar
d” to
sum
mar
ize k
ey m
etric
s an
d an
ticip
ated
im
prov
emen
t initia
tives
for d
istrib
utio
n to
full s
take
hold
er b
ase
- wa
y to
form
alize
feed
back
col
lect
ion/
use
Bu
reau
sho
uld
cons
ider
dev
elop
ing
para
llel te
am to
inte
rnal
Co
nsum
er R
espo
nse
stee
ring
com
mitte
e via
a fo
rmal
(rot
atin
g m
embe
rshi
p) s
take
hold
er a
dviso
ry b
oard
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
47
Fact
or
Scor
e Su
mm
ary
of P
erfo
rman
ce
Prio
rity
Find
ing
/ Rec
omm
enda
tion
OUT
COM
ES:
Link
age
betw
een
mea
sure
men
t and
co
ntin
uous
pro
cess
im
prov
emen
t
An
ecdo
tal u
se o
f sta
keho
lder
feed
back
to tw
eak
exist
ing
proc
esse
s (e
.g.,
bank
por
tal)
Co
ntac
t cen
ter:
call s
corin
g an
d ot
her r
elat
ed Q
A/pr
oces
s im
prov
emen
t und
erwa
y wi
th s
mal
l QC
team
Bu
t for
mal
mea
sure
men
t sys
tem
s la
rgel
y at
ear
liest
sta
ges
of
deve
lopm
ent t
oday
out
side
of in
take
/con
tact
cen
ter
Med
ium
Bure
au s
houl
d co
ntin
ue w
ith re
leva
nt Q
C an
d da
ta h
ires
to
reso
urce
mea
sure
men
t, in
spec
tion,
repo
rting
and
rela
ted
anal
ysis
– a
core
par
t of C
R’s
man
date
OUT
COM
ES: Q
uality
of
repo
rting
to in
form
fu
ture
CFP
B sc
ope,
re
duce
com
plai
nts
over
time
No
spe
cific
oper
atio
nal g
oals
in p
lace
to d
ate
rega
rdin
g m
inin
g co
ntac
ts c
lass
ified
as “f
eedb
ack”
Lo
w
Bu
reau
sho
uld
cont
inue
with
rele
vant
QC
and
data
hire
s to
re
sour
ce m
easu
rem
ent,
insp
ectio
n, re
porti
ng a
nd re
late
d an
alys
is
Bu
reau
sho
uld
esta
blish
sin
gle
mas
ter d
ashb
oard
cor
e op
erat
ing
met
rics
on s
lides
30
and
31
Bu
reau
sho
uld
set in
tern
al s
tand
ards
for m
inin
g fe
edba
ck, b
oth
as a
saf
egua
rd to
ens
ure
inco
rrect
ly co
ded
feed
back
is re
rout
ed
if nec
essa
ry, a
nd to
pro
vide
fresh
dat
a/an
alys
is on
pro
cess
im
prov
emen
t, em
ergi
ng c
onsu
mer
con
cern
s/ne
eds,
etc
.
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
49
Section 4: Information Technology
4.1 Scope of Audit
In this section, we establish scope boundaries for our audit of CFPB’s performance in the area of Information Technology (IT). Our evaluation of the bureau’s performance in this area has three distinct components: (1) an evaluation of selected IT investments to date (i.e., project performance); (2) an evaluation of current-state operations of the IT investment process; and (3) an evaluation of IT investment process maturity. In order to evaluate performance across these three areas, we leveraged three complementary performance frameworks. In the table below, we introduce the source for each performance framework, and explain how we used the framework to support the performance audit.
Performance Framework Evaluation Use Federal IT Dashboard (http://www.itdashboard.gov/)
Establishes a framework for evaluating the performance of individual IT investments or projects, in terms of cost, schedule, and other performance metrics that are established by agency CIOs.
GAO Report: Assessing Risks and Returns: A Guide for Evaluating Federal Agencies' IT Investment Decision-making (AIMD-10.1.13)
Establishes a framework for evaluating how well an agency is selecting and managing its IT resources, and for identifying improvement opportunities.
GAO Report: Information Technology Investment: A Framework for Assessing and Improving Process Maturity (GAO-04-394G)
Establishes a framework for evaluating the maturity of an IT investment process. This report enhances the guidance from AIMD-10.1.13 through the creation of a formal maturity model for investment management—the Information Technology Investment Management (ITIM) Framework.
4.1.1 Evaluation of Major IT Investments
The first component of our performance audit was an evaluation of selected IT projects that are currently underway at CFPB. The purpose of this component was to determine whether existing IT investments are proceeding according to established plans with respect to scope, schedule, and budget – and whether they are meeting the defined requirements. In order to evaluate performance in this dimension, we used the standards and criteria that defined by the Federal IT Dashboard (FITD). The FITD is a standardized method for all federal agencies to report on the health of their major IT projects, and to support decisions regarding the investment and management of IT resources.
4.1.2 Evaluation of the IT Investment Process
The second component of our performance audit is an evaluation of operations of the IT investment process. The purpose of this component is to evaluate the overall planning and control of the IT investment process, including the methods that CFPB uses to select and manage IT projects, as well as the standards that are used to determine whether IT investments are supporting strategic goals. In
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
50
order to evaluate performance in this dimension, we used the standards and criteria that are defined in GAO’s framework for evaluating Federal IT investment decision-making. This framework is based on three inter-connected dimensions:
Selection. Setting priorities and making decisions regarding which IT projects should be funded.
Control. Managing projects throughout the development lifecycle in order to ensure that projects deliver their intended results.
Evaluation. Comparing actual results against expected results and assessing the project’s impact on mission performance.
4.1.3 Evaluation of IT Investments Maturity
The third component of our performance audit was an evaluation of the maturity of CFPB’s IT investment process. In order to evaluate performance in this dimension, we used the standards and criteria that are defined by GAO’s Information Technology Investment Management (ITIM) Framework. This framework defines five progressive stages of maturity for IT investment management – and for each stage, it describes a set of criteria that must be in place to achieve that stage.
GAO developed the ITIM to be used both as a tool for organizational improvement, and as a standard against which to judge the maturity of an organization’s IT investment management process. The specific maturity levels and associated criteria of the ITIM framework are described in greater detail in Section 4.2.3.2.
4.2 Evaluation Criteria
The purpose of this section is to describe the evaluation criteria for this review area (associated findings and recommendations are presented in Section 4.3). As with other areas of performance, our audit focuses on three sets of criteria: (1) compliance with legal requirements; (2) achievement of organizational goals; and (3) alignment with performance standards, best practices, and/or benchmarks.
4.2.1 Compliance with the Law
The Dodd-Frank Act did not specifically establish requirements and/or evaluation criteria in the area of IT Systems. However, there are laws that establish standards and criteria for IT systems and IT investment processes. Chief among them are the following:
E-Government Act of 2002 (Public Law 107-347, 116 Stat. 2899, 44 U.S.C. § 101, H.R. 2458/S. 803), United States statute enacted on December 17, 2002, with an effective date for most provisions of April 17, 2003. Its stated purpose is to improve the management and promotion of electronic government services and processes by establishing a Federal Chief Information Officer within the Office of Management and Budget, and by establishing a framework of measures that require using Internet-based information technology to improve citizen access to government information and services, and for other purposes.
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Federal Information Security Management Act of 2002 (FISMA) (44 U.S.C. § 3541, et seq). United States federal law enacted in 2002 as Title III of the E-Government Act of 2002 (Pub.L. 107-347, 116 Stat. 2899). The act recognized the importance of information security to the economic and national security interests of the United States. The act requires each federal agency to develop, document, and implement an agency-wide program to provide information security for the information and information systems that support the operations and assets of the agency, including those provided or managed by another agency, contractor, or other source.
Confidential Information Protection and Statistical Efficiency Act (CIPSEA). This statute prohibits disclosure or release, for non-statistical purposes, of information collected under a pledge of confidentiality. Under CIPSEA, data may not be released to unauthorized persons.
The Clinger-Cohen Act of 1996 (formally the Information Technology Management Reform Act, Division E of Public Law 104-106) The Clinger-Cohen Act requires federal agencies to focus on the results they are achieving through IT investments. Specifically, the act introduces much more rigor and structure into how agencies approach the selection and management of IT projects. Among other things, the head of each agency is required to implement a process for maximizing the value and assessing and managing the risks of the agency's IT acquisitions.
The Paperwork Reduction Act of 1995 (PRA) (Public Law 104-13). PRA requires agencies to use information resources to improve the efficiency and effectiveness of their operations and fulfillment of their missions. It emphasizes achieving program benefits and meeting agency goals through the effective use of IT.
The Federal Acquisition Streamlining Act of 1994 (FASA) (Public Law 103-355). Title V of FASA requires agencies to define cost, schedule, and performance goals for federal acquisition programs (including IT projects) and to monitor these programs to ensure that they remain within prescribed tolerances. If a program falls out of tolerance (failure to meet 90 percent of cost, schedule, and performance goals), FASA gives the agency head the authority to review, and if necessary terminate, the program.
4.2.2 Achievement of Organizational Goals
In order to assess achievement of organizational goals, we evaluated the progress that CFPB has made towards measurable goals that are documented in its planning artifacts. The bullets below describe the five goals that were documented in CFPB’s Information Technology Roadmap:
Hire/Retain World Class Talent o Be great at sourcing world-class candidates o Seek people who share our values and align with our mission o Establish an interview process that is rigorous and fair o Demonstrate commitment to the professional development of our team o Create an environment that fosters work/life balance & career growth
Lay the Technology Foundation
o Place top priority on safety and securing the public trust o Deliver geographically agnostic, reliable access to our network
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o Use technology to simplify and improve processes for our customers, don’t impose burdens on them
o Seek enterprise-wide solutions to common problems o Value openness and transparency in all we do
Drive the Data Architecture o Develop systems and policies to clean, merge, and store data o Help acquire key data and facilitate expansive analyses o Structure environments to support wide array of analysis tools o Centralize collection through an enterprise wide data warehouse o Provide exceptional tools for reporting and analysis
Provide Customer Focused IT Services
o Constantly monitor CFPB needs and external technology trends o Focus on understanding problems first, technology second o Provide responsible governance over the IT platform portfolio o Make it faster, easier, and better to work with IT o Be ambassadors internally and externally for great IT
Create Engaging Digital Experiences o Deliver an engaging website experience with useful tools o Build data and content APIs for external use o Develop and integrate applications for internal use o Focus on a highly useful mobile experience o Provide open source code for other government agencies to use
4.2.3 Alignment with Performance Standards and Best Practices
In order to evaluate alignment with performance standards and best practices, we used the standards and criteria defined by three federal IT performance frameworks: (1) GAO’s Guide for Evaluating IT Investment Decision-Making; (2) GAO’s Information Technology Investment Management (ITIM) Framework; and (3) the Federal IT Dashboard. Each of these performance frameworks is made up of several dimensions of performance, as well as criteria and/or examples that constitute effective performance. Below, we describe the dimensions and criteria that make up each of the three performance frameworks.
4.2.3.1 GAO’s Guide for Evaluating IT Investment Decision-making
In order to evaluate the IT investment management process, we use standards and criteria defined by GAO in its Guide for Evaluating IT Investment Decision-Making.3 GAO’s framework is built around three phases of IT investment management (Selection, Control and Evaluation) – as well as three levels of review (Process, Data and Decisions). As illustrated in the diagram below, the intersection of these three phases and review levels creates a matrix of nine performance areas.
3 GAO, Assessing Risk and Returns: A Guide for Evaluating Federal Agencies’ IT Investment Decision-making, GAO-AIMD-10.1.13 (Washington, D.C.: February 1997).
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Within each performance area, GAO has defined specific criteria or “key elements”, which we use to evaluate performance for the CFPB’s IT investment process. For example, specific criteria related to the Selection dimension include the following:
Does the organization have a defined process for submitting and screening new funding proposals for management consideration? Is this process established in policy guidance?
Does the selection process define (1) what information is to be submitted, (2) who must approve (screen) the information prior to formal submission, (3) how a determination will be made about where in the organization the project will be reviewed, and (4) the stages of management review?
Are roles, responsibilities, and authority for people and offices involved in the screening process clearly defined?
4.2.3.2 GAO’s Information Technology Investment Management (ITIM) Framework
In order to evaluate the CFPB’s investment management maturity, we use standards and criteria that are defined in GAO’s ITIM Framework.4 This framework is built around five progressive stages of maturity for IT investment management (Stages 1 through 5). As illustrated in the diagram below, each stage of maturity is indicated by the presence of certain “critical processes”. For example, critical processes for advancement past Stage 1 maturity include the creation of an investment review
4 GAO, Information Technology Investment Management: A Framework for Assessing and Improving Process Maturity, GAO-04-394G (Washington, D.C.: March 2004).
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
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board and development of an investment selection process. We use the presence of these critical processes as criteria to evaluate the maturity CFPB’s IT investment management process.
4.2.3.3 Federal IT Dashboard (FITD)
The FITD is a standardized method for all federal agencies to report on the health of their major IT projects. Following the FITD methodology, each IT project receives an overall investment rating, which is a composite of three component scores (cost, schedule, and Evaluation by Agency CIO).5 The “Evaluation by Agency CIO” dimension is determined by each agency CIO, using a pre-defined set of evaluation factors and criteria, as illustrated in the table below. The bullets below describe the criteria that we used to evaluate IT project performance:
Risk Management o Does a risk management strategy exist? o Are risks well understood by senior leadership? o Is the risk log current and complete? o Are risks clearly prioritized? o Are mitigation plans in place to address risks?
Requirements Management
o Are investment objectives clear? o Is scope controlled? o Are requirements complete, clear and validated? o Are appropriate stakeholders involved in requirements definition?
Contractor Oversight o Is the acquisition strategy defined and managed via an Integrated Program Team?
5 Federal IT Dashboard, FAQ - For Agencies, http://www.itdashboard.gov/faq-agencies (September 2, 2011)
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o Does the agency receive key reports, such as earned value reports, current status, and risk logs?
o Is the agency providing appropriate management of contractors such that the government is monitoring, controlling, and mitigating the impact of any adverse contract performance?
Historical Performance o Are there significant deviations from planned cost and schedule? o Are lessons learned and best practices incorporated and adopted?
Human Capital o Is there a qualified management and execution team for the IT investments? o Are contracts in place to support the investment? o Is there a low turnover rate among project resources?
Cost. The cost criterion is assessed in terms of percent cost variance. Cost variance of less
than 10% results in a “Green” stoplight rating; cost variance of 10% to <30% results in a “Yellow” rating; and cost variance of 30% or more results in a “Red” rating.
Schedule. The Schedule criterion is assessed in terms of percent schedule variance. Schedule variance of less than 10% results in a “Green” stoplight rating; schedule variance of 10% to <30% results in a “Yellow” rating; and schedule variance of 30% or more results in a “Red” rating.
4.3 Findings and Recommendations
In this section, we present key findings and recommendations for each of the three sets of criteria included in the performance audit: (1) compliance with the legal requirements; (2) achievement of organizational goals; and (3) alignment with performance standards, best practices, and/or benchmarks. The supporting tables referenced throughout this section are presented at the end of the section.
4.3.1 Compliance with Legal Requirements
Table 12 presents our assessment of the CFPB’s compliance with legal requirements. Each row in this table corresponds to a specific legal requirement. For each requirement, we describe the progress that the bureau has demonstrated to date, along with recommendations for future action. The bullets below highlight our key findings and recommendations:
CFPB has developed an innovative web presence that helps the bureau to both educate and listen to consumers, in accordance with eGovernment Act objectives. We recommend that CFPB continue to expand its delivery of services via the Internet as planned, specifically including the addition of “products” to the domain of the Consumer Information System (CIS).
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CFPB has complied with key elements of the E-Government Act of 2002, including the Federal Information Security Management Act (FISMA) and the Confidential Information Protection and Statistical Efficiency Act (CIPSEA). Specifically, CFPB obtained authority to operate (ATO) for: (1) connectivity to the Treasury infrastructure; and (2) protection of confidential and/or personal information in CIS. We recommend that CFPB continue their approach to retaining personal information and conducting FISMA audits. CFPB has already demonstrated behaviors consistent with this, for example, by submitting System of Record Notices (SORN) that address items such as the individuals covered by the system, categories of records in the system, purpose of the system, categories of users of the system, storage, retrievability, and safeguards.
CFPB has aligned its information technology assets with its strategic missions, in accordance with the Clinger-Cohen Act of 1996. This alignment is managed by the IRB, and documented at a high level through the IRB dashboard. Specifically, the IRB dashboard identifies each of the Initial Systems (technology assets) being developed by CFPB, and links each asset to either: (1) a specific element of CFPB’s mission; or (2) a specific enterprise or business service. The IT department enters proposed IT investments into the dashboard as proposals are received from the business areas and the IRB reviews each investment on a weekly basis. The IRB review is the management mechanism for implementing the capital planning and investment control processes for IT systems.
4.3.2 Achievement of Organizational Goals
Table 13 presents our assessment of the CFPB’s achievement of organizational goals. Each row in this table corresponds to a specific organizational goal. For each goal, we describe the progress that the bureau has demonstrated to date, along with recommendations for future action. The bullets below highlight our key findings and recommendations
CFPB should continue to build human capital for the IT function. CFPB has made appropriate progress towards this goal. It has named a Chief Technology Officer, Chief Information Officer and Chief Information Security Officer – and it has established a productive IT organization through an integrated team of government and contractor personnel. We recommend that the IT organization target an 8% to 10% ratio of IT staff to total CFPB staff.
CFPB should form an IT program management office (PMO) to facilitate a continuation of its customer focus and implementation of key systems. The IT department has achieved its goal of laying the technical foundation for CFPB and providing customer focused services. Adopting a PMO approach would provide a means of standardizing artifacts across projects and facilitate development of a project database to support evaluations and a “lessons learned” process.
CFPB has used Information Technology (IT) to support customer service. With the development of the Consumer Information System (CIS) and the CFPB website, the IT department has created an engaging digital experience. The use of Tell Your Story and Know Before You Owe on the website offer further evidence of progress in this area. We
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
57
recommend that the IT organization continue its emphasis on this goal and conduct a formal review of the usability of the website.
4.3.3 Alignment with Performance Standards and Best Practices
Table 14 (Investment Review Process) presents our assessment of the CFPB’s performance with respect to IT Investment Management. Each row in this table corresponds to an evaluation factor specified in GAO ITIM framework. Table 15 presents our summary assessment of performance for three IT projects that are currently being managed by the CFPB (eDiscovery, Consumer Information System, and Cornerstone). For each row in these tables, we provide the following information: (1) a rating of CFPB’s performance to date, using a stoplight scale (i.e., Red, Yellow or Green); (2) a summary of demonstrated performance; (3) the priority of future progress in this area; and (4) recommendations for future action. The bullets below highlight our key findings and recommendations.
CFPB should initiate a formal evaluation process for IT investments. We found that the
project selection and project control components of CFPB’s IT investment management process met GAO standards, as defined in the Information Technology Investment Management (ITIM) Framework. We recommend that CFPB initiate a formal investment evaluation process, now that it has a growing set of historical data regarding the performance of IT projects. The evaluation process should be a function of the Investment Review Board (IRB) and supported by the PMO.
CFPB’s IT investment management process is operating at “stage two” of the five-stage maturity model defined by the GAO’s ITIM Framework. In order to progress to stage three, CFPB should build upon existing IRB processes, with an emphasis on: (1) grouping similar investments together and developing an IT portfolio; (2) creating and maintaining portfolio selection criteria; (3) examining the merits of each IT investment in the context of the portfolio; and (4) using an Enterprise Architecture to help align IT investments with strategic objectives.
CFPB should develop and apply standard methods to manage risk and cost variance for IT investments. Using the Federal IT Dashboard as a performance standard to evaluate three projects, we found evidence of good requirements management, contractor oversight, human capital, and schedule management. We recommend that the IT department apply a standard method to monitor and manage cost variance, even though many projects are performed on a fixed cost basis. Also, we recommend that CFPB adopt a standardized approach to documenting risks and mitigation strategies.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
58
Tab
le 1
2: C
omp
lian
ce w
ith
Leg
al R
equ
irem
ents
Lega
l Req
uire
men
t De
mon
stra
ted
Perfo
rman
ce
Find
ing
/ Rec
omm
enda
tion
E-G
over
nmen
t Act
(eG
ov) o
f 200
2 –
Prom
otes
use
of e
lect
roni
c go
vern
men
t ser
vices
Title
III:
Fede
ral I
nfor
mat
ion
Secu
rity
Man
agem
ent A
ct (F
ISM
A) o
f 20
02 –
Req
uire
s ea
ch fe
dera
l age
ncy
to d
evel
op, d
ocum
ent,
and
impl
emen
t an
agen
cy-w
ide
prog
ram
to p
rovid
e in
form
atio
n se
curit
y
Title
V: C
onfid
entia
l Inf
orm
atio
n Pr
otec
tion
and
Stat
istic
al
Effic
ienc
y Ac
t (CI
PSEA
). Pr
ohib
its d
isclo
sure
or r
elea
se, f
or n
on-
stat
istica
l pur
pose
s, o
f info
rmat
ion
colle
cted
und
er a
ple
dge
of
conf
iden
tiality
. Und
er C
IPSE
A, d
ata
may
not
be
rele
ased
to
unau
thor
ized
pers
ons.
• M
ultip
le in
itiativ
es d
emon
stra
te th
e CF
PB’s
focu
s on
in
form
ing
and
liste
ning
to c
onsu
mer
s in
inno
vativ
e wa
ys (C
FPB
webs
ite, K
now
Befo
re Y
ou O
we,
publ
ishin
g le
ader
ship
cal
enda
rs).
• Ap
poin
ted
a Ch
ief I
nfor
mat
ion
Offic
er a
nd C
hief
In
form
atio
n Se
curit
y O
fficer
. •
Com
plet
ed in
itial p
hase
of t
he C
onsu
mer
Info
rmat
ion
Syst
em (C
IS),
inclu
ding
the
abilit
y to
rece
ive c
redi
t ca
rd c
ompl
aint
s fro
m c
onsu
mer
s.
• Re
ceive
d Au
thor
izatio
n To
Ope
rate
(ATO
) for
in
frast
ruct
ure
and
conn
ectiv
ity to
Tre
asur
y ne
twor
k an
d sy
stem
s. F
ISM
A pr
oces
ses
are
impl
emen
ted.
•
Syst
ems
such
as
CIS
and
eDisc
over
y –
which
may
co
ntai
n co
nfid
entia
l or p
erso
nally
iden
tifiab
le
info
rmat
ion
(PII)
–ha
ve s
afeg
uard
s to
pre
vent
the
rele
ase
of th
is in
form
atio
n to
una
utho
rized
per
sons
.
Cont
inue
with
pla
ns to
impr
ove
the
webs
ite a
nd
furth
er d
evel
op C
IS.
Deve
lop
perfo
rman
ce m
easu
res
for e
-go
vern
men
t tha
t are
: (1)
citiz
en-c
entri
c; (2
) pr
oduc
tivity
rela
ted;
and
(3) l
inke
d to
the
CFPB
’s St
rate
gic
Plan
s.
Cond
uct P
rivac
y Im
pact
Ass
essm
ents
for a
ll ap
plica
ble
IT s
yste
ms.
Deve
lop
annu
al e
-Gov
ernm
ent R
epor
t to
Cong
ress
.
Impl
emen
t ann
ual F
ISM
A au
dits
.
Esta
blish
pol
icies
and
pro
cedu
res
to s
uppo
rt th
e de
tect
ion,
ass
essm
ent,
and
mitig
atio
n of
risk
s th
at
coul
d re
sult f
rom
una
utho
rized
or i
napp
ropr
iate
us
e of
org
aniza
tiona
l info
rmat
ion.
The
Clin
ger-C
ohen
Act
of 1
996
(form
ally
the
Info
rmat
ion
Tech
nolo
gy
Man
agem
ent R
efor
m A
ct, D
ivisio
n E
of P
ublic
Law
104
-106
) - R
equi
res
fede
ral a
genc
ies
to fo
cus
on th
e re
sults
they
are
ach
ievin
g th
roug
h IT
in
vest
men
ts.
• Te
chno
logy
inve
stm
ents
are
tied
to C
FPB
miss
ion
elem
ents
(e.g
., CI
S –
cons
umer
pro
tect
ions
; eD
iscov
ery,
law
enfo
rcem
ent)
or to
non
-miss
ion
elem
ents
that
dire
ctly
impa
ct th
e m
issio
n (e
.g.,
hum
an
capi
tal, f
inan
cial m
anag
emen
t).
• Pr
otot
ype
impl
emen
tatio
ns a
re u
sed
to re
duce
the
risk
of IT
pro
ject
s, a
s in
the
case
of t
he C
IS “b
ridge
” pro
ject
. •
Agile
dev
elop
men
t met
hods
are
use
d to
del
iver
bene
fits in
man
agea
ble
incr
emen
ts.
Stan
d up
a fo
rmal
Pro
gram
Man
agem
ent O
ffice
for C
FPB
Info
rmat
ion
Tech
nolo
gy.
Impl
emen
t a
portf
olio
app
roac
h to
IT in
vest
men
t man
agem
ent,
inclu
ding
ana
lysis
of re
turn
s on
eac
h in
vest
men
t.
The
Pape
rwor
k Re
duct
ion
Act (
PRA)
of 1
995
- Req
uire
s ag
encie
s to
us
e in
form
atio
n re
sour
ces
to im
prov
e th
e ef
ficie
ncy
and
effe
ctive
ness
of
thei
r ope
ratio
ns a
nd fu
lfillm
ent o
f the
ir m
issio
ns.
• M
ultip
le IT
inve
stm
ents
(e.g
., CI
S, e
-Disc
over
y,
webs
ite) u
tilize
info
rmat
ion
tech
nolo
gy to
: (1)
impr
ove
the
perfo
rman
ce o
f bur
eau
miss
ion;
(2) p
rom
ote
acce
ss to
info
rmat
ion;
and
/or (
3) m
inim
ize th
e bu
rden
of
info
rmat
ion
colle
ctio
n on
the
publ
ic.
• Th
e IR
B da
shbo
ard
dem
onst
rate
s th
at C
FPB
appl
ies
info
rmat
ion
reso
urce
s to
sup
port
thei
r miss
ion.
Cont
inue
to id
entify
mea
ning
ful IT
inve
stm
ents
an
d us
e th
e es
tabl
ished
IRB
proc
ess
to s
elec
t an
d tra
ck th
e IT
inve
stm
ents
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
59
Lega
l Req
uire
men
t De
mon
stra
ted
Perfo
rman
ce
Find
ing
/ Rec
omm
enda
tion
The
Fede
ral A
cqui
sitio
n St
ream
linin
g Ac
t (FA
SA) o
f 199
4 - R
equi
res
agen
cies
to d
efin
e co
st, s
ched
ule,
and
per
form
ance
goa
ls fo
r fed
eral
ac
quisi
tion
prog
ram
s (in
cludi
ng IT
pro
ject
s) a
nd to
mon
itor t
hese
pr
ogra
ms
to e
nsur
e th
at th
ey re
mai
n wi
thin
pre
scrib
ed to
lera
nces
.
• CF
PB p
roje
cts
have
def
ined
bud
gets
and
sch
edul
es
that
are
app
rove
d by
the
IRB.
All p
roje
cts
repo
rt st
atus
in
form
atio
n to
the
IRB,
and
pro
gres
s is
mon
itore
d th
roug
h th
e IR
B da
shbo
ard.
How
ever
, sta
tus
info
rmat
ion
does
not
inclu
de e
arne
d va
lue
repo
rts o
r fo
rmal
risk
logs
.
Cont
inue
the
IRB
proc
ess
and
add
a PM
O
com
pone
nt to
man
age
cost
and
sch
edul
ing
info
rmat
ion
on a
sta
ndar
dize
d ba
sis.
Cons
ider
em
ploy
ing
Earn
ed V
alue
Man
agem
ent (
EVM
) or
othe
r pro
ject
man
agem
ent m
etric
s as
nee
ded
as
the
orga
niza
tion
grow
s.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
60
Tab
le 1
3: A
chie
vem
ent
of O
rgan
izat
ion
al G
oals
Org
aniz
atio
nal G
oal
Dem
onst
rate
d Pe
rform
ance
Fi
ndin
g / R
ecom
men
datio
n
Hire
/Ret
ain
Wor
ld C
lass
Tal
ent
• Ke
y po
sitio
ns (C
IO, C
TO, a
nd C
ISO
) are
fille
d, a
dditio
nal p
ositio
ns a
re
bein
g fill
ed in
acc
orda
nce
with
hig
h le
vel p
lans
, and
con
sultin
g su
ppor
t is
in p
lace
to a
ddre
ss p
eak-
load
wor
k.
• Th
e IT
org
aniza
tion
shou
ld c
ontin
ue to
add
app
ropr
iate
sta
ff to
mai
ntai
n a
ratio
of b
etwe
en 8
% to
10%
as
com
pare
d to
th
e to
tal s
taff
of C
FPB.
Lay
the
Tech
nolo
gy F
ound
atio
n
• DC
loca
tions
con
nect
ed, r
egio
nal lo
catio
n in
frast
ruct
ure
and
conn
ectio
ns
depl
oyed
, har
dwar
e fo
r inc
omin
g em
ploy
ees
proc
ured
& d
eplo
yed,
ex
trane
t des
igne
d, m
igra
tion
to C
FPB
LAN/
WAN
pla
nned
, inde
pend
ent
disa
ster
reco
very
/bac
k up
pla
n (c
urre
ntly
falls
und
er T
reas
ury’s
pla
n)
unde
r dev
elop
men
t.
• Th
e IT
org
aniza
tion
shou
ld c
ontin
ue to
incr
ease
its n
etwo
rk
capa
city.
Dev
elop
and
test
a C
ontin
uity
of O
pera
tions
Pla
n (C
OO
P) th
at is
spe
cific
to C
FPB,
with
in th
e Tr
easu
ry's
larg
er
plan
.
Drive
the
Data
Arc
hite
ctur
e
• En
terp
rise-
wide
dat
a st
rate
gy h
as b
een
deve
lope
d an
d in
clude
s da
ta
arch
itect
ure,
tool
/sof
twar
e ar
chite
ctur
e, a
nd d
ata
secu
rity
• Pr
oces
ses
and
proc
edur
es a
re d
efin
ed
• Sh
ort t
erm
, mid
-term
, and
long
-term
pla
ns a
re d
ocum
ente
d
• Th
e IT
org
aniza
tion
shou
ld fo
rmal
ize a
n or
gani
zatio
nal
taxo
nom
y an
d en
terp
rise
data
dict
iona
ry.
Prov
ide
Cust
omer
Foc
used
IT S
ervic
es
• eD
iscov
ery
solu
tion
has
been
acq
uire
d an
d in
itial d
ata
has
been
ca
ptur
ed.
• In
itial fu
nctio
nality
of t
he C
IS s
yste
m (c
redi
t car
d co
mpl
aint
s) is
onl
ine
and
addi
tiona
l pro
duct
type
s (m
ortg
ages
, stu
dent
loan
s, e
tc.)
are
sche
dule
d fo
r sup
port
• Co
ntin
ued
supp
ort is
pro
vided
to th
e IR
B •
Inhe
rited
sys
tem
s ar
e be
ing
supp
orte
d •
Asse
t Tra
ckin
g an
d Co
mpl
ianc
e To
olkit
/Risk
Ana
lytics
sys
tem
pla
ns h
ave
been
app
rove
d by
the
IRB
• Th
e IT
org
aniza
tion
shou
ld fo
rmal
ize p
roje
ct a
rtifa
cts
per
what
is ty
pica
lly fo
und
in a
PM
O.
Crea
te E
ngag
ing
Digi
tal E
xper
ienc
es
• Fe
edba
ck m
echa
nism
s de
velo
ped
for C
FPB
webs
ite (e
.g.,
Cred
it Car
d Co
mpl
aint
s, T
ell Y
our S
tory
, Ope
n fo
r Com
men
t).
• He
at m
ap d
ispla
ys o
f fee
dbac
k fro
m K
now
Befo
re Y
ou O
we p
roje
ct.
• W
ebsit
e us
e st
atist
ics
• Th
e IT
org
aniza
tion
shou
ld p
erfo
rm fo
rmal
use
r tes
ting
of
the
publ
ic fa
cing
webs
ites
once
the
sites
are
mor
e m
atur
e.
This
shou
ld in
clude
hea
t map
s, u
sabi
lity te
sts,
clic
k co
unts
, et
c.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
61
Tab
le 1
4: A
lign
men
t w
ith
Per
form
ance
Sta
nd
ard
s (I
nve
stm
ent
Rev
iew
Pro
cess
)
Fact
or
Scor
e Su
mm
ary
of P
erfo
rman
ce
Prio
rity
Find
ing
/ Rec
omm
enda
tion
Sele
ctio
n
Al
l IT in
vest
men
ts g
reat
er th
an $
100K
are
eva
luat
ed b
y th
e IR
B an
d do
cum
ente
d on
the
IRB
Dash
boar
d
Th
e IR
B ha
s a
sele
ctio
n pr
oces
s in
pla
ce th
at in
clude
s co
st a
nalys
is,
alte
rnat
ives
anal
ysis,
sch
edul
ing,
and
gov
ernm
ent c
ost e
stim
ates
. De
cisio
ns
are
docu
men
ted
with
exp
lana
tions
. Exc
eptio
ns to
the
proc
ess
are
for
emer
genc
ies
and
a sig
n-of
f she
et is
requ
ired
Th
e IR
B ha
s es
tabl
ished
info
rmat
ion/
repo
rting
requ
irem
ents
for c
andi
date
in
vest
men
ts a
nd fo
r in-
flight
pro
ject
s.
IR
B da
shbo
ard
is up
date
d we
ekly.
Pro
ject
s ar
e m
onito
red
base
d on
in
form
atio
n fro
m th
e da
shbo
ard.
Med
ium
Th
e IR
B wa
s es
tabl
ished
ver
y ea
rly in
the
CFPB
org
anizi
ng
proc
ess.
It h
as m
et w
eekly
in o
rder
to a
ddre
ss c
ritica
l and
fast
m
ovin
g ne
eds.
As
the
orga
niza
tion
mat
ures
the
IRB
shou
ld: (
1)
adop
t a p
ortfo
lio a
ppro
ach
to IT
inve
stm
ent m
anag
emen
t; (2
) de
velo
p fo
rmal
met
rics
and
stan
dard
s fo
r pro
ject
sco
ring
and
sele
ctio
n; a
nd (3
) ret
ain
cons
isten
t per
form
ance
dat
a. T
he
portf
olio
app
roac
h wi
ll be
need
ed to
sup
port
budg
et fo
rmul
atio
n go
ing
forw
ard.
Cont
rol
Pe
rform
ance
met
rics
are
mai
ntai
ned,
but
EVM
cal
cula
tions
are
not
pe
rform
ed.
The
IRB
does
not
man
date
the
use
of s
pecif
ic m
etric
s or
th
resh
olds
, and
it do
es n
ot a
pply
diffe
rent
met
rics
for p
roje
cts
of d
iffere
nt s
ize.
Ex
cel s
prea
dshe
ets
are
used
to m
aint
ain
inve
stm
ent in
form
atio
n
Af
ter A
ctio
n Re
views
are
con
duct
ed a
nd d
ocum
ente
d
Di
spos
ition
proc
ess
is be
ing
plan
ned
– no
t yet
requ
ired
due
to e
arly
stag
e of
or
gani
zatio
n
CF
PB tr
acks
exp
endi
ture
s as
socia
ted
with
IT in
vest
men
ts th
at a
re h
andl
ed
thro
ugh
Mem
oran
da o
f Und
erst
andi
ng (M
OU)
with
ext
erna
l org
aniza
tions
(e
.g.,
Trea
sury
).
High
Th
e IT
org
aniza
tion
mai
ntai
ns p
roje
ct c
ontro
l thro
ugh
spre
adsh
eets
and
var
ious
repo
rting
ven
ues
(slid
es fo
r IRB
). As
th
e or
gani
zatio
n m
atur
es, a
“PM
O-lit
e” a
ppro
ach
is re
com
men
ded
to s
tand
ardi
ze p
roje
ct a
rtifa
cts,
pro
vide
a ce
ntra
l po
rtal to
reta
in p
roje
ct a
rtifa
cts,
form
alize
cos
t and
sch
edul
e va
rianc
e re
porti
ng, a
nd e
stab
lish
stan
dard
ized
met
rics
typi
cal o
f a
mat
ure
proj
ect m
anag
emen
t app
roac
h. T
he IR
B pr
oces
s sh
ould
hav
e de
taile
d do
cum
enta
tion
and
supp
ortin
g po
licy
that
do
veta
ils w
ith th
e PM
O.
Eval
uatio
n
Th
e IR
B co
nduc
ted
its fir
st fo
rmal
revie
w of
an
in-fl
ight
pro
ject
in S
epte
mbe
r 20
11.
The
stat
us re
port
deve
lope
d fo
r thi
s in
itial p
roje
ct re
view
will b
e us
ed
as a
tem
plat
e fo
r fut
ure
proj
ect r
evie
ws.
Th
e IR
B pr
oces
s is
eval
uate
d an
d re
vised
as
the
orga
niza
tion
mat
ures
Th
ere
is ve
ry lim
ited
post
-impl
emen
tatio
n re
view
info
rmat
ion
beca
use
proj
ects
are
in th
e ea
rly p
hase
s of
the
syst
ems
deve
lopm
ent li
fecy
cle
Med
ium
In
add
ition
to th
e ad
hoc
Afte
r Act
ion
Revie
ws (A
AR) t
hat t
he IT
or
gani
zatio
n cu
rrent
ly pe
rform
s, s
tand
ardi
zed
and
regu
larly
sc
hedu
led
revie
ws a
re re
com
men
ded.
Thi
s wi
ll be
facil
itate
d by
es
tabl
ishin
g th
e PM
O fu
nctio
n an
d pr
ojec
t man
agem
ent p
orta
l th
at w
ill ca
ptur
e da
ta n
eede
d fo
r the
revie
ws. T
his
is hi
ghly
reco
mm
ende
d as
maj
or p
roje
cts
com
plet
e th
e im
plem
enta
tion
phas
e (fi
rst r
elea
ses)
. Pos
t Im
plem
enta
tion
Revie
w (P
IR) s
houl
d be
com
e an
IRB
agen
da ite
m.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
62
Tab
le 1
5: A
lign
men
t w
ith
Per
form
ance
Sta
nd
ard
s (I
T P
roje
ct P
erfo
rman
ce)
Fact
or
Scor
e Su
mm
ary
of P
erfo
rman
ce
Prio
rity
Find
ing
/ Rec
omm
enda
tion
Risk
M
anag
emen
t
Al
l pro
ject
s re
port
risks
and
mitig
atio
n st
rate
gies
to th
e IR
B on
a w
eekly
ba
sis.
Howe
ver,
none
of t
he th
ree
sam
pled
pro
ject
s m
aint
ains
a fo
rmal
ris
k re
gist
er..
O
n th
e CI
S pr
ojec
t, ris
k wa
s m
anag
ed th
roug
h th
e de
velo
pmen
t of a
sim
plifie
d “b
ridge
” sys
tem
, in p
aral
lel w
ith d
evel
opm
ent o
f the
targ
et s
tate
sy
stem
. Th
e br
idge
sys
tem
ser
ved
as a
fallb
ack
optio
n, a
s we
ll as
a pr
otot
ype
for t
he ta
rget
sta
te s
yste
m.
O
n th
e Co
rner
ston
e pr
ojec
t, ce
rtain
risk
s ar
e m
itigat
ed b
y le
vera
ging
a
prov
en, T
reas
ury-
wide
sol
utio
n.
Med
ium
De
velo
pmen
t of a
sta
ndar
dize
d ap
proa
ch fo
r com
mun
icatin
g an
d tra
ckin
g po
tent
ial r
isk a
nd m
itigat
ion
stra
tegi
es w
ould
be
bene
ficia
l. Thi
s sh
ould
focu
s on
a “r
isk re
gist
er” a
ppro
ach
and
ultim
atel
y fe
ed a
pro
ject
dat
abas
e.
Requ
irem
ents
M
anag
emen
t
O
n al
l pro
ject
s, a
ltern
ative
tech
nolo
gy s
olut
ions
wer
e ev
alua
ted.
On
CIS
proj
ect,
Forre
ster
Res
earc
h wa
s en
gage
d to
obt
ain
info
rmat
ion
on b
est
prac
tices
.
Al
l pro
ject
s en
gage
d in
requ
irem
ents
elic
itatio
n, d
ocum
enta
tion,
and
m
anag
emen
t act
ivitie
s –
at v
aryin
g le
vels
of ri
gor.
O
n th
e eD
iscov
ery
proj
ect,
the
Elec
troni
c Di
scov
ery
Refe
renc
e M
odel
(an
indu
stry
sta
ndar
d) w
as u
sed
as a
bas
elin
e fo
r req
uire
men
ts a
nalys
is.
Agile
met
hods
wer
e us
ed in
sup
port
of re
quire
men
ts m
anag
emen
t.
O
n th
e Co
rner
ston
e pr
ojec
t, a
mas
ter l
ist o
f sys
tem
requ
irem
ents
was
de
velo
ped
by T
reas
ury
and
cros
swal
ked
agai
nst c
apab
ilitie
s of
the
Corn
erst
one
solu
tion.
O
n th
e CI
S pr
ojec
t, de
velo
pmen
t of t
he “b
ridge
” sys
tem
aid
ed in
the
elici
tatio
n an
d va
lidat
ion
of re
quire
men
ts.
Scop
e of
CIS
requ
irem
ents
for
initia
l pro
ject
pha
se w
as d
riven
in p
art b
y sc
hedu
le c
onst
rain
ts.
Low
As
the
orga
niza
tion
grow
s a
tool
or m
etho
dolo
gy s
houl
d be
us
ed to
sta
ndar
dize
the
appr
oach
to re
quire
men
ts
man
agem
ent.
Re
quire
men
ts s
houl
d be
bas
elin
ed a
t maj
or p
roje
ct
mile
ston
es.
Base
lined
requ
irem
ents
sho
uld
be u
sed
for
test
ing
and
to m
onito
r sco
pe v
aria
nce.
As
the
orga
niza
tion
mat
ures
, pro
ject
requ
irem
ents
sho
uld
be
trace
d up
ward
to o
rgan
izatio
nal c
apab
ilitie
s, in
ord
er to
de
mon
stra
te a
lignm
ent w
ith C
FPB
stra
tegy
.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
63
Fact
or
Scor
e Su
mm
ary
of P
erfo
rman
ce
Prio
rity
Find
ing
/ Rec
omm
enda
tion
Cont
ract
or
Ove
rsig
ht
Fo
r all p
roje
cts:
(1) a
n ac
quisi
tion
stra
tegy
was
dev
elop
ed, d
ocum
ente
d,
and
appr
oved
by
the
IRB;
and
(2) a
form
al s
ched
ule
was
deve
lope
d, a
nd
prog
ress
aga
inst
the
sche
dule
is re
porte
d.
Al
l pro
ject
s re
port
stat
us in
form
atio
n to
the
IRB;
pro
gres
s is
mon
itore
d th
roug
h th
e IR
B da
shbo
ard.
Sta
tus
info
rmat
ion
does
not
inclu
de e
arne
d va
lue
repo
rts o
r for
mal
risk
logs
.
Fo
r all p
roje
cts,
con
tract
or o
vers
ight
app
ears
to b
e ap
prop
riate
and
ef
fect
ive. O
n th
e CI
S pr
ojec
t, ad
optio
n of
agi
le m
etho
dolo
gy b
y bo
th
gove
rnm
ent a
nd c
ontra
ctor
team
s co
ntrib
uted
to e
ffect
ive c
omm
unica
tion
and
coor
dina
tion.
Low
Th
e co
ntra
ctor
ove
rsig
ht fu
nctio
n is
prim
arily
per
form
ed a
t the
pr
ojec
t leve
l, with
sum
mar
y re
porti
ng to
the
IRB.
As
the
orga
niza
tion
grow
s, a
uni
form
eva
luat
ion
mec
hani
sm w
ill be
ap
prop
riate
.
Hist
orica
l Pe
rform
ance
No
ne o
f the
pro
ject
s ex
hibi
t sig
nific
ant d
evia
tions
from
pla
nned
sch
edul
e or
bud
get.
Af
ter A
ctio
n Re
views
are
con
duct
ed a
nd re
porte
d.
Si
nce
CFPB
is in
its e
arly
stag
e of
form
atio
n, th
ere
is lim
ited
info
rmat
ion
rega
rdin
g hi
stor
ical p
erfo
rman
ce o
f pro
ject
s. A
s of
9/2
1/20
11, t
he IR
B ha
d on
ly co
nduc
ted
one
form
al re
view
of p
roje
ct p
erfo
rman
ce (e
-FO
IA p
roje
ct).
Med
ium
Si
nce
the
orga
niza
tion
was
rece
ntly
form
ed, h
istor
ical
perfo
rman
ce h
as n
ot b
een
avai
labl
e or
nec
essa
ry. L
esso
ns
lear
ned
have
bee
n do
cum
ente
d in
Afte
r Act
ion
Repo
rts. G
oing
fo
rwar
d, a
dditio
nal s
truct
ure
will b
e re
quire
d in
ord
er to
es
tabl
ish p
erfo
rman
ce m
etric
s, d
evel
op a
nalyt
ical m
etho
ds,
and
inte
rnal
ize le
sson
s le
arne
d ac
ross
the
orga
niza
tion.
Hum
an C
apita
l
Fo
r all s
ampl
ed p
roje
cts,
per
sonn
el a
re in
pla
ce to
exe
cute
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Independent Performance Audit of CFPB Operations and Budget October 15, 2011
65
Section 5: Communications and Transparency
5.1 Scope of Audit
In order to evaluate CFPB’s performance in the area of Communications and Transparency, we examined the extent to which the bureau has: (1) complied with relevant laws and regulations; (2) achieved organizational goals and objectives; and (3) aligned with industry best practices. Successful communications plans consider the following critical components as a baseline for building a strategy.
Determine Goals, Objectives and Strategies – Determine the end state CFPB would like to reach with respect to communications and transparency initiatives and the strategies to achieve that goal.
Identify Audiences – Identify the specific audiences CFPB wants to engage.
Establish Policies and Processes – Make certain that there are internal policies and processes to ensure that CFPB’s communications strategy can be properly executed.
Develop Key Messages – Develop messages for key audiences, noting that while messages can be different, message consistency across the organization is important.
Identify Vehicles and Materials for Delivery – Identify the vehicles and materials for message delivery that are appropriate for the targeted audiences and materials used.
Define Metrics – Define what success means and identify the metrics CFPB will use to determine how successful it has been in executing its communications strategy.
We recognize that CFPB is a new bureau and as such may not have implemented all aspects of its plan or determined all appropriate criteria. However, we were able to examine the plans it has developed and executed against thus far, along with those it has developed and will execute in the future, assess its performance to date and offer recommendations for consideration in the future. Our audit focuses on major accomplishments and plans, including internal planning documents, memos and processes, media rollout plans, master outreach plans, reports, and media coverage.
5.2 Evaluation Criteria
The purpose of this section is to describe the evaluation criteria for this review area (associated findings and recommendations are presented in Section 5.3). As with other areas of performance, our audit focuses on three sets of criteria: (1) compliance with legal requirements; (2) achievement of organizational goals; and (3) alignment with performance standards, best practices, and/or benchmarks.
5.2.1 Compliance with the Law
The bullets below describe specific provisions of the Dodd-Frank Act and other applicable laws and regulations that establish compliance requirements or standards in the area of Communications and Transparency.
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Section 1013(a)(5) of the Dodd-Frank Act requires that CFPB have an Ombudsman whose responsibilities include focusing on problem resolution between the bureau and regulated entities or other parties.
Section 1014 of the Dodd-Frank Act requires that CFPB create a Consumer Advisory Board
(CAB) that advises and consults with the bureau in the exercise of its functions and provides information on emerging practices in the consumer financial products or services industry, including regional trends and concerns.
Title 10, Section 1013(e) of the Dodd-Frank Act requires that CFPB create the Office of
Servicemember Affairs. A key objective for the Office as delineated in the statute is to “educate and empower servicemembers and their families to make better informed decisions regarding consumer financial products and services”.
Title 10, Section 1013(g) of the Dodd-Frank Act requires that CFPB create the Office of
Financial Protection for Older Americans, defined as individuals 62 years or older. The goal for this office is to establish programs that provide financial literacy and counseling and to work with other community and non-profit organizations that assist seniors.
Title 10, Section 1035 of the Dodd-Frank Act requires that CFPB designate a Private
Education Loan Ombudsman. Included in the duties prescribed for the Ombudsman is a charge to “ensure coordination in providing assistance to and serving borrowers seeking to resolve complaints related to their private education or Federal student loans”.
Title 10, Section 1013(d) of the Dodd-Frank Act requires that CFPB establish the Office of
Financial Education (OFE), which is responsible for educating consumers to help them make better financial decisions. This office is charged to reach out directly to consumers and to coordinate with other offices within CFPB to carry out its mandates.
Freedom of Information Act (FOIA) (Public Law 89-554) – FOIA provides all citizens
with the right of access to federal agency records or information. When a written request for information is received by a federal agency, the agency is required to disclose those records, unless they can be lawfully withheld under nine specific exemptions outlined in the statute. The burden is on the government, not the public, to provide explanation for why information cannot be released.
E-Government Act of 2002 (Public Law 107-347) – The E-Government Act of 2002's
purpose is to improve electronic government services by establishing a Federal Chief Technology Officer, located in the Office of Management and Budget, and creating a framework that requires Internet-based information technology to improve the transparency of and access to government information and services for citizens. The statute includes the Federal Information Security Management Act of 2002 (FISMA) and the Confidential Information Protection and Statistical Efficiency Act (CIPSEA).
Federal Funding and Accountability Transparency Act (FFATA) (Public Law 109-
282) – FFATA requires that all entities or organizations receiving federal funds as of FY 2007
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are disclosed to the public, with the intent to empower all citizens with the ability to hold the government accountable for spending decisions. All information on federal awards are available to the public via www.usaspending.gov, providing transparent information to the public on government spending decisions.
5.2.2 Achievement of Organizational Goals
In order to assess achievement of organizational goals, we evaluated the progress that the bureau has made towards measurable goals that are identified in CFPB planning documents. The bullets below describe the specific organizational goals that are included in our analysis. These goals were derived from the CFPB 2011 Public Outreach Plan, planning documents for the Office of Community Affairs, discussions with CFPB stakeholders, and the Office of Consumer Education and Engagement’s (CEE) 6-Month planning document.
The CFPB 2011 Public Outreach Plan established the following objectives: (1) maintain public support; (2) highlight the positive impact the bureau can and will have in the lives of American consumers; and (3) demonstrate the tangible benefits of the bureau to ordinary Americans. To achieve these broad objectives, the bureau has pursued the following organizational goals:
o Build familiarity with the CFPB brand o Engage the public o Explain policy deliverables in plain English o Illustrate the consumer impact o Maximize bureau resources
The Office of Community Affairs’ first year goals established the following objectives: (1) be
a bridge to the community, civil rights and consumer groups by showing the face of CFPB to the public and bringing timely, relevant, reliable information from the field into the bureau to help inform its work; and (2) be a thought leader on financial inclusion by serving the CFPB and the public with up-to-date information and new ideas about developments in expanding financial opportunity. To achieve these broad objectives, the Office of Community Affairs has pursued the following organizational goals:
o Touch most significant national and regional consumer, civil rights, and grassroots advocacy organizations in the financial services space (~200).
o Develop “early warning” information from the field and make available to all CFPB reports and studies from consumer, civil rights, and community groups about impacts of specific financial service products and practices on neighborhoods and communities.
o Create a searchable content resource of those reports and studies, and provide periodic updates for all CFPB staff of the input received from these groups.
o Be a resource to consumer, civil rights and nonprofit organizations, and help all parts of the CFPB to access knowledge and information from those groups.
Within the CEE, the Office of Consumer Engagement established the following overall
objectives: (1) engage the public with new and timely content in multiple formats; (2) build a team with the tools to succeed; (3) deploy an editorial content management system for ConsumerFinance.gov and content we offer elsewhere via electronic channels; and (4) design
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a blueprint for the CFPB “consumer experience” and develop and deploy interactive product and service offerings. Given the early stage of the Office of Consumer Engagement, we evaluated the following deliverables defined by the Office within the CEE’s 6-Month Plan:
o CFPB’s shared vision of the role of engagement and the desired impact on the public of our engagement work
o Organizational structure, position descriptions, career ladders, recruitment plan, and policies to support the work (example, “blog on other sites” policy)
o Blueprint for the CFPB “consumer experience,” concepts for CFPB product and service offerings such as interactive tools, plus plan with timeline to bring one or more of those more significant tools to fruition
o IT solution for editorial workflow and content management system for ConsumerFinance.gov
o Improved business process for generating and clearing content for use on our website and other electronic channels
o 8-10 blog posts each month generated by the Engagement Office, plus support for financial education content in post and tip form generated by the OFE (in addition to posts from around the bureau)
o Consistent promotion of our money education content such as tip of the day to other sites/channels
o Web portals for the empowerment offices plus OFE (My Fi) and Fair Lending o One to two initial offerings to engage the public on money issues or money decision-
making in close cooperation with OFE o Design and implementation of calendar for use of direct email tool o Web streaming capacity (for Office of Servicemember Affairs convening,
enforcement hearings)
Also within CEE, the Office of Servicemember Affairs (OSA) outlined the following overall objectives: (1) educate and empower servicemembers and their families to make better-informed financial decisions; (2) work with Consumer Response to monitor complaints from military and responses to those complaints by CFPB and other federal and state agencies; (3) coordinate efforts among federal and state agencies regarding consumer protection measures relating to consumer financial products and services used by military families; and (4) serve as a subject-matter expert on military consumer financial matters, both within and outside the CFPB. Given the early stage and youth of the Offices of Servicemember Affairs, we evaluated the following deliverables defined by OSA within the CEE’s 6-Month Plan:
o Develop military content for website/social media o Host convening in October concerning best practices in offering financial products to
military o Evaluate financial education at military basic training o Develop revised curriculum for new recruits in coordination with Dept. of Defense o Provide military expertise for Consumer Response: scripts, FAQs, referrals, tailored
assistance o Raise awareness of CFPB/OSA through media, speeches and outreach to business and
government
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It is important to note that CFPB stakeholders consistently expressed that their primary objective is to support the overall mission of the organization, as prescribed by the statute, as well as the stated mission and vision of the bureau. Discussions with CFPB stakeholders revealed the following additional anecdotal goals, including:
o Adhere to all appropriate federal mandates o Maintain the spirit of transparency that was “baked into the organization” at its
inception o Educate the public on what CFPB is and what it is doing to help ordinary Americans o Meet with community bankers from all 50 states
5.2.3 Alignment with Performance Standards and Best Practices
In order to assess achievement of performance standards and best practices, we evaluated the progress CFPB has made against the framework outlined below.
Goals, Objectives and Strategies. A successful communications plan should include well-defined goals and objectives, and the necessary strategies to achieve those goals.
Audiences. Audiences that are important to the CFPB should be identified and an initial assessment should be made regarding their current perception or awareness level of CFPB.
Policies and Processes. Internal policies and processes must be in place in order to provide accountability for distributing external communications and creating transparency for the public.
Key Messages. Appropriate messages for different key audiences must be developed.
Vehicles and Materials. The appropriate materials and vehicles for delivery should be developed and determined for each key audience; there should also be an assessment of integration of those materials into the overall communications and transparency strategy.
Metrics of Success. In order to determine success, metrics for success (and success itself) should be clearly defined.
5.3 Findings and Recommendations
In this section, we present key findings and recommendations for each of the three sets of criteria included in the performance audit: (1) compliance with the legal requirements; (2) achievement of organizational goals; and (3) alignment with performance standards, best practices, and/or benchmarks. The supporting tables referenced throughout this section are presented at the end of the section.
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5.3.1 Compliance with Legal Requirements
Table 16 presents our assessment of the CFPB’s compliance with legal requirements. Each row in this table corresponds to a specific legal requirement. For each requirement, we describe the progress that the bureau has demonstrated to date, along with recommendations for future action. The bullets below highlight our key findings and recommendations
CFPB has complied with most requirements where we would expect to see progress in a bureau of this age. In particular, the CFPB has demonstrated exemplary progress in developing and implementing a process for complying with FOIA and has, in our judgment, appropriately complied with applicable laws governing this and other federal government agencies.
CFPB should continue to move toward filling positions and offices mandated by the Dodd-Frank Act. The Dodd-Frank Act mandated the creation of six offices that perform communications functions. The bureau is statutorily unable to create a Consumer Advisory Board (CAB) until a Director has been approved by Congress. However, a detailee is on staff currently serving in the Ombudsman role, which does not require a Director in place. In addition to filling the Ombudsman position with a permanent employee as soon as possible, we recommend that CFPB continue to move forward with developing plans for CAB and be prepared to staff positions as soon as a Director is approved.
5.3.2 Achievement of Organizational Goals
Tables 17 through 21 present our assessment of the CFPB’s achievement of organizational goals. Each row in this table corresponds to a specific organizational goal. For each goal, we describe the progress that the bureau has demonstrated to date, along with recommendations for future action. The bullets below highlight our key findings and recommendations with regard to overall organizational goals and those specifically outlined by the CFPB 2011 Public Outreach Plan, the Office of Community Affairs, anecdotal discussions with the bureau’s stakeholders, and those outlined by CEE. Overall, CFPB Communications and Transparency stakeholders have demonstrated the appropriate levels of performance one would expect to see in a young organization.
CFPB has made a great deal of progress in achieving a number of its overall goals. In particular, the bureau as a whole has placed the utmost importance on engaging consumers, the general public, and consumer and civil rights advocacy groups; its efforts are evident (and successful) and should continue to drive the bureau going forward. Efforts could include, for example, continuing to think about and develop long-term ways to help consumers express the financial difficulties they face on an everyday basis. Finally, the CFPB should consider ways to publicly demonstrate its leadership in this area.
CFPB should further coordinate its mission, vision and values statements across mediums. Currently, the CFPB has defined its mission, vision and values, but they differ slightly across platforms. While slight variances are to be expected given the differing audiences each CFPB office is trying to reach (e.g., lawmakers, consumers and the general public), in places where the CFPB’s statutory purpose, mission, vision, and values are printed,
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it should consider reducing inconsistencies. Doing so will build brand strength over time and allow multiple audiences to fully understand how the CFPB views itself.
CFPB should use its overall strategy to develop coordinated strategies across divisions. The CFPB is in the process of developing a bureau-wide strategy document for the CFPB moving forward. We understand that individual divisions, (i.e., External Affairs, Consumer Engagement and Education, etc.), will use this plan to inform the plans of individual offices within the CFPB. This idea will help to formalize the continuity across divisions that already exists informally and will synchronize goals, plans and defined success.
5.3.3 Alignment with Performance Standards and Best Practices
Tables 22 through 27 present our assessment of the CFPB’s performance with respect to each of the six performance factors outlined in Section 5.2.3 (i.e., Goals and Objectives, Audiences, Policies and Processes, Strategies and Messages, Vehicles and Materials, and Metrics of Success). Each row in the tables corresponds to a goal, audience, policy, strategy, vehicle, or metric. For each, we provide the following information: (1) a rating of CFPB’s performance to date, using a stoplight scale (i.e., Red, Yellow or Green); (2) a summary of demonstrated performance; (3) the priority of future progress in this area, based on the importance of the performance area for a start-up organization; and (4) recommendations for future action. The bullets below highlight our key findings and recommendations. Key Findings
CFPB has made engaging the public its top priority. The CFPB as a whole has made substantial progress in communicating with and engaging the public, whether it is through digital mediums (e.g., the CFPB website and blog), events (e.g., townhall meetings, CFPB speeches), or one-on-one conversations. It is also clear that the CFPB has placed a high-level of importance on interacting with multiple audiences on a regular basis, including consumer groups, the private sector, policymakers, and the media. Internal documents reveal that the CFPB has gone to great lengths to meet with members of the private sector, particularly those that will be most affected by CFPB’s new authority, to keep them up to date on the direction the bureau is headed, and ask them for feedback.
CFPB has adopted and maintained a strong interest in being transparent and accountable to the public. This is something that, as many told us, has been baked into the organization since its inception. The transparency of the bureau was something former Special Advisor Elizabeth Warren strongly believed in, and is something that has translated to all aspects of the CFPB. The bureau is being transparent in numerous ways, including by posting the calendars of top officials on the website.
There is a strong “teamwork” mentality throughout the CFPB. In all of our discussions
with stakeholders, no individual in any division viewed his or her role as separate from the actions of other divisions. Part of what has made CFPB so successful to date, in our view, is the flow of information between offices and teams. For example, the Offices of Consumer Engagement and Education and External Affairs are constantly working together to determine
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how best to reach key audiences and how to share information across teams. Additionally, the Office of Servicemember Affairs is highly coordinated with other offices within CEE and External Affairs.
Nearest-Term Opportunities for Improvement (High Priority)
CFPB should continue work on developing additional language capabilities. The CFPB
has made efforts to engage populations that have been most severely impacted by the financial crisis. Currently the CFPB offers its 800 number in 189 languages, and is in the process of co-developing a Spanish version of the new single mortgage disclosure document from the Know Before You Owe initiative and a fully functional Spanish version of the website. Co-developing materials takes longer but it creates a much better product for consumers. CFPB should continue to move forward in developing additional language capabilities to allow all of its key constituencies to participate in the dialogue it is fostering.
CFPB should determine definitions of success. Defining success is always difficult,
particularly in communications. Often times there is no one number or metric that can be used to define success. While we understand the difficulty, offices within CFPB concerned with external communications should work together to develop documented definitions. Throughout our discussions with stakeholders, there were many times when the definition of success was simply understood. While this practice is useful internally, the CFPB would benefit greatly from putting agreed-upon definitions on paper. Doing so reinforces accountability and gives outsiders, including new staff, the ability to immediately understand what success looks like.
Mid-Term Opportunities for Improvement (Medium Priority)
CFPB should maintain policymaker interaction. Discussions with CFPB stakeholders
revealed a proactive view toward interacting with policymakers, including members of Congress, and state and local officials. Members of the CFPB team have testified before Congress on eleven occasions, have made numerous trips to the Hill to brief both Congressional staff and members of Congress, and regularly provide updates on news coming out of the bureau. CFPB should continue to engage policymakers and work toward establishing a two-way dialogue through which both the bureau and policymakers can gain important insight from one another.
CFPB should continue to engage key audiences. One of the challenges for the CFPB as it
continues to grow, mature and assume more responsibility is to continue the high level of engagement it has fostered thus far. The bureau has set a very high standard for itself and may encounter difficulties living up to that standard. An increase in staff will assist in meeting the growing responsibilities of the bureau.
Longer-Term Opportunities for Improvement (Low Priority)
CFPB should develop searchable content capability. One of Community Affairs’ goals is to have searchable resource content available for all reports, studies and communications with
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target groups. Community Affairs is currently working with the IT department to develop the digital infrastructure needed for such a resource. CFPB should continue to develop this capability.
CFPB should continue to develop internal processes. CFPB has implemented several internal processes, including a Clearance Memo that requires all external communications go through the Executive Secretary to ensure message continuity, a Media Memo that educates all CFPB staff on policies and procedures about dealing with the media, and multiple FOIA procedures that insure requests are responded to on time and that the appropriate people within CFPB are made aware of important requests. As discussed above, one of the challenges for CFPB moving forward will be maintaining the high level of performance the bureau has demonstrated to date. It will be important moving forward that all CFPB staff is properly educated on all internal processes and that the high level of performance continues. For example, as the CFPB continues to grow and assume more responsibility, there will undoubtedly be an increase in FOIA requests. Having a tight internal process in place (as CFPB does) will be imperative for high quality of performance to continue.
Feedback from External Stakeholders Melanie Pustay, Director of the Office of Information Policy (OIP), U.S. Department of Justice The CFPB’s policy towards FOIA was “impressive”, including its initiative when requesting a meeting with OIP to discuss the set up of its FOIA office. The request was “notable,” particularly because of how quick the inquiry was. Also impressive was the amount of thought CFPB representatives demonstrated throughout our discussion about FOIA. When the meeting ended, it was clear CFPB had thought of everything and that there were “no gaps.” Particularly impressive was CFPB’s enthusiasm for structuring an internal FOIA system that has the ability to take advantage of e-Discovery. A new technology, e-Discovery will bring instrumental change to the FOIA world as it will further facilitate document searches, and will de-duplicate documents electronically. Utilizing e-Discovery is a completely new idea, and the fact that CFPB was already thinking about its advantages and utilization demonstrated that the CFPB was “thinking outside the box.” It is very possible that CFPB’s attitudes towards and processes around FOIA could become the industry standard. As a new bureau opening its doors in the computer-age, CFPB has the unique opportunity to launch a system without the burden of trying to overhaul an entrenched, paper-based system. As CFPB continues to implement its eFOIA program, it will be one of the few agencies truly taking advantage of new technologies in this area. Melanie Pustay is the Director of the Office of Information Policy (OIP) at the U.S. Department of Justice (DOJ). OIP is the lead FOIA office for all of the federal government serving 97 different agencies; it disseminates the legal requirements around FOIA to those agencies and provides counsel on how to follow the Attorney General’s FOIA guidelines.
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Travis Plunkett, Legislative Director, Consumer Federation of America “It seems to have been a priority” for CFPB to engage with the financial industry, consumer and industry groups, and the public. CFPB has made an effort to be a transparent bureau, and in that sense, they “look to be functioning differently than most federal regulators.” Of particular note are the CFPB website and initial rulemaking efforts, which seem to be functioning in a more transparent manner. CFPB has tried to draw in audiences that are not typically involved in the rulemaking process, and has encouraged early input from these groups. CFPB began the process far ahead of its deadline and made a concerted effort to engage industry and consumer groups to get their thoughts. In the case of mortgage disclosure forms (i.e., Know Before You Owe), “I like the way they are reaching out to the public to see how [the revised documents] actually work.” The whole process of working with the public and interested parties is more open “and at least initially, more promising” in terms of engaging the public. The CFPB’s website, is like “no other federal government website I’ve seen,” as are the reports on credit scores and remittances the CFPB issued. Both reports are “well done,” and it is refreshing that financial jargon is not used, particularly because they are aimed at reaching a general consumer audience. Though the CFPB is still new, very soon it will need to move beyond the general categories of issues it is discussing and start addressing specific issues they have identified as important, based on discussions with industry, consumer and public discussions. Also, regardless of the political climate, CFPB needs to continue to focus on what it can do—not what it can’t do—because it still has a great deal of authority even without a Director in place. Travis Plunkett is the Legislative Director for the Consumer Federation of America. Select Members of the Press The following is a compilation of “not-for-attribution” conversations had with several members of the press about the CFPB regarding its efforts around communications and transparency. While most consumers don’t follow the actions of federal agencies, the CFPB has a unique mandate in that it is a consumer-oriented bureau. Given that, the expectations related to reaching the public are different, and the CFPB’s name recognition among consumers is still very limited. Considering the age of the bureau and its limited staff, CFPB has done a good of job getting the message out regarding its mission and how it intends to serve the public interest. Its message is very proactive and consistent, and it invites the public to participate and provide information. The CFPB’s website is good, easy to navigate and consumer friendly. CFPB has fully embraced transparency, as evidenced by its near-real-time posting of schedules for senior officials on the CFPB website, with few redactions. As compared to other federal agencies, CFPB is more proactive in this area. CFPB has also been very public about meetings it has held with industry and consumer groups, and on FOIA requests, it has been very responsive. Too often, CFPB and other federal agencies provide interviews on background (i.e., the reporter cannot use any quotes
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from the discussion in his/her reporting), then provide written quotes after the interview. This occurs even when the discussion topic does not warrant such an approach. The Dodd-Frank Act—and by extension, CFPB—has been a subject of great debate in Washington. As such, it is important for the Bureau to be transparent and avoid major missteps. CFPB is still in the process of collecting data so it remains to be seen how it will utilize the information it gathers to aid its regulatory function, but if it continues the trend it has established so far, the bureau will be successful. Case Studies The following case studies are summaries of actions within the CFPB that we felt warranted special recognition as practices that demonstrate how the CFPB works to fulfill its mandate. They are based on conversations with staff and verified in documents provided. Community Affairs Situation: Congress charged the CFPB with addressing issues that are most fundamental to consumers’ everyday lives. The challenges the CFPB faced include determining how best to reach consumers to understand what issues are most important to them and how to create a feedback loop between the bureau and consumers. Action: CFPB developed a working relationship with the advocacy group Americans for Financial Reform (AFR) that included regular communications, meetings and joint efforts. The CFPB worked with AFR to understand key issues and held regular forums with subject matter experts to discuss those key issues. Additionally, CFPB worked directly with AFR to identify grassroots organizations on the ground that could serve as conduits for the delivery of CFPB’s financial services. Results: Through the working relationship with AFR, the CFPB was able to create a conduit to consumers and a feedback loop between itself and consumers. CFPB has met with numerous AFR working groups on topics including consumer response, new media, research and data collection, and mortgages. Doing so has provided invaluable resources, data and assistance, particularly leading up to the establishment of CFPB’s own consumer response system. Regular meetings with AFR working groups allows CFPB subject matter experts to have access to external sources of information that become part of internal discussions across the bureau. Small Business, Community Banks & Credit Unions Situation: When CFPB began its work, the bureau recognized the need to develop a feedback loop between itself and the institutions it would supervise and provide rules for (i.e., large banks and community banks and credit unions, respectively). The challenge was not necessarily getting CFPB’s voice to the institutions, but rather creating a way to hear from them. Action: CFPB recognized the difficulty associated with trying to engage each and every community bank and consumer union across the country. CFPB made the decision that in addition to direct outreach, it would work through trade associations. One such association was the Independent Community Bankers of America (ICBA).
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
76
Results: Through its relationship with trade associations like ICBA, CFPB was able to receive consistent flows of information on community banks’ feelings on current and future CFPB initiatives. CFPB’s relationship with ICBA also helped it reach its ambitious goal of meeting with community bankers from all 50 states in less than a year.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
77
Tab
le 1
6: C
omp
lian
ce w
ith
Leg
al R
equ
irem
ents
Lega
l Req
uire
men
t De
mon
stra
ted
Perfo
rman
ce
Find
ing
/ Rec
omm
enda
tion
CFPB
is re
quire
d by
sec
tion
1013
(a)(5
) of t
he D
odd-
Fran
k Ac
t to
have
an
Om
buds
man
who
se re
spon
sibilit
ies
inclu
de fo
cusin
g on
pro
blem
reso
lutio
n be
twee
n th
e CF
PB a
nd re
gula
ted
entiti
es o
r oth
er th
ird p
artie
s.
• CF
PB h
as e
valu
ated
the
Om
buds
man
fu
nctio
n wi
thin
oth
er a
genc
ies
and
cond
ucte
d an
app
ropr
iate
leve
l of in
tern
al p
lann
ing.
• Th
e po
sitio
n of
Om
buds
man
is m
anda
ted
by th
e Do
dd-
Fran
k Ac
t in th
e O
ffice
of E
xter
nal A
ffairs
and
its ro
le w
ithin
th
e or
gani
zatio
n is
an im
porta
nt o
ne. A
det
aile
e in
this
posit
ion
coul
d fa
ce s
ome
chal
leng
es in
fulfil
ling
a ro
le th
at
requ
ires
inte
rnal
inve
stig
atio
n gi
ven
that
em
ploy
ees
coul
d vie
w hi
m/h
er a
s te
mpo
rary
and
be
less
than
fully
co
oper
ative
.
• Th
us w
e re
com
men
d th
at th
e CF
PB fil
l the
posit
ion
with
a
full-t
ime
empl
oyee
as
soon
as
poss
ible
.
CFPB
is re
quire
d by
sec
tion
1014
of t
he D
odd-
Fran
k Ac
t to
crea
te a
Co
nsum
er A
dviso
ry B
oard
that
adv
ises
and
cons
ults
with
the
CFPB
in th
e ex
ercis
e of
its fu
nctio
ns a
nd p
rovid
es in
form
atio
n on
em
ergi
ng p
ract
ices
in
the
cons
umer
finan
cial p
rodu
cts
or s
ervic
es in
dust
ry, in
cludi
ng re
gion
al
trend
s an
d co
ncer
ns.
• CF
PB h
as e
valu
ated
the
Advis
ory
Boar
d fu
nctio
n wi
thin
oth
er a
genc
ies
and
deve
lope
d a
draf
t rep
ort in
Jul
y 20
11 th
at o
utlin
es b
est
prac
tices
rela
ted
to B
oard
func
tions
, pot
entia
l ru
les
to g
over
n th
e Bo
ard,
miss
ion,
and
lega
l re
quire
men
ts.
• W
hile
the
Cons
umer
Adv
isory
Boa
rd h
as a
n im
porta
nt
func
tion
with
in th
e or
gani
zatio
n an
d is
man
date
d by
the
Dodd
-Fra
nk A
ct in
Ext
erna
l Affa
irs, b
y la
w th
e Bo
ard
cann
ot b
e es
tabl
ished
unt
il the
Dire
ctor
of t
he C
FPB
is in
pl
ace.
• Th
us w
e re
com
men
d th
at p
repa
ratio
ns c
ontin
ue s
o th
e Bo
ard
can
be c
reat
ed a
s so
on a
s po
ssib
le fo
llowi
ng th
e ap
prov
al o
f a D
irect
or.
CFPB
is re
quire
d by
Title
10,
Sec
tion
1013
(e) o
f the
Dod
d-Fr
ank
Act t
o cr
eate
the
Offic
e of
Ser
vicem
embe
r Affa
irs.
A ke
y ob
ject
ive fo
r the
Offic
e as
del
inea
ted
in th
e st
atut
e is
to “e
duca
te a
nd e
mpo
wer s
ervic
emem
bers
an
d th
eir f
amilie
s to
mak
e be
tter i
nfor
med
dec
ision
s re
gard
ing
cons
umer
fin
ancia
l pro
duct
s an
d se
rvice
s”.
• CF
PB h
as c
reat
ed th
e O
ffice
of
Serv
icem
embe
r Affa
irs.
• In
our
judg
men
t, ba
sed
on th
e in
form
atio
n pr
ovid
ed, t
he
CFPB
has
met
its o
blig
atio
ns in
this
area
.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
78
Lega
l Req
uire
men
t De
mon
stra
ted
Perfo
rman
ce
Find
ing
/ Rec
omm
enda
tion
CFPB
is re
quire
d by
Title
10,
Sec
tion
1013
(g) o
f the
Dod
d-Fr
ank
Act t
o cr
eate
the
Offic
e of
Fin
ancia
l Pro
tect
ion
for O
lder
Am
erica
ns, d
efin
ed a
s in
divid
uals
62 y
ears
or o
lder
. Th
e go
al fo
r thi
s of
fice
is to
est
ablis
h pr
ogra
ms
that
pro
vide
finan
cial li
tera
cy a
nd c
ouns
elin
g an
d to
wor
k wi
th
othe
r com
mun
ity a
nd n
on-p
rofit
orga
niza
tions
that
ass
ist s
enio
rs
• As
out
lined
in D
odd-
Fran
k, C
FPB
is no
t re
quire
d to
hav
e cr
eate
d th
e O
ffice
of
Fina
ncia
l Pro
tect
ion
for O
lder
Am
erica
ns u
ntil
Janu
ary
21, 2
012.
Alth
ough
the
Offic
e of
Fi
nanc
ial P
rote
ctio
n fo
r Old
er A
mer
icans
is
not e
valu
ated
in th
is re
port,
sin
ce th
e O
ffice
was
crea
ted
on A
ugus
t 28,
the
actin
g di
rect
or
of th
e O
ffice
met
with
num
erou
s go
vern
men
tal o
ffices
and
sta
keho
lder
s in
volve
d in
issu
es a
ffect
ing
Old
er A
mer
icans
, co
nsist
ent w
ith C
FPB’
s st
atut
ory
man
date
. Th
e pe
rman
ent A
ssist
ant D
irect
or w
ill be
on
boar
d on
Oct
ober
17.
• In
our
judg
men
t, ba
sed
on th
e in
form
atio
n pr
ovid
ed, t
he
CFPB
has
met
its o
blig
atio
ns in
this
area
.
CFPB
is re
quire
d by
Title
10,
Sec
tion
1035
of t
he D
odd-
Fran
k Ac
t to
desig
nate
a P
rivat
e Ed
ucat
ion
Loan
Om
buds
man
. In
clude
d in
the
dutie
s pr
escr
ibed
for t
he O
mbu
dsm
an is
a c
harg
e to
“ens
ure
coor
dina
tion
in
prov
idin
g as
sista
nce
to a
nd s
ervin
g bo
rrowe
rs s
eekin
g to
reso
lve
com
plai
nts
rela
ted
to th
eir p
rivat
e ed
ucat
ion
or F
eder
al s
tude
nt lo
ans”
.
• As
out
lined
in th
e Do
dd-F
rank
Act
, CFP
B is
not r
equi
red
to h
ave
desig
nate
d a
Priva
te
Educ
atio
n Lo
an O
mbu
dsm
an u
ntil O
ctob
er
21, 2
011.
Give
n th
at, t
he fu
nctio
n of
Priv
ate
Educ
atio
n Lo
an O
mbu
dsm
an is
not
ev
alua
ted
in th
e re
mai
nder
of t
his
repo
rt.
• De
signa
te a
Priv
ate
Educ
atio
n Lo
an O
mbu
dsm
an b
y th
e da
te p
resc
ribed
in D
odd-
Fran
k.
CFPB
is re
quire
d by
Title
10,
Sec
tion
1013
(d) o
f the
Dod
d-Fr
ank
Act t
o es
tabl
ish th
e O
ffice
of F
inan
cial E
duca
tion,
whi
ch is
resp
onsib
le fo
r ed
ucat
ing
cons
umer
s to
hel
p th
em m
ake
bette
r fin
ancia
l dec
ision
s. T
his
offic
e is
char
ged
to re
ach
out d
irect
ly to
con
sum
ers
and
to c
oord
inat
e wi
th
othe
r offic
es w
ithin
CFP
B to
car
ry o
ut its
man
date
s.
• CF
PB h
as c
reat
ed th
e O
ffice
of F
inan
cial
Educ
atio
n. H
owev
er, d
ue to
the
newn
ess
of
the
offic
e at
this
time,
it is
not e
valu
ated
in th
e re
mai
nder
of t
his
repo
rt.
• In
our
judg
men
t, ba
sed
on th
e in
form
atio
n pr
ovid
ed, t
he
CFPB
has
met
its o
blig
atio
ns in
this
area
.
CFPB
is re
quire
d to
com
ply
with
the
Free
dom
of I
nfor
mat
ion
Act (
FOIA
). FO
IA p
rovid
es a
ll citiz
ens
with
the
right
of a
cces
s to
fede
ral a
genc
y re
cord
s or
info
rmat
ion.
Whe
n a
writte
n re
ques
t for
info
rmat
ion
is re
ceive
d by
a
fede
ral a
genc
y, th
e ag
ency
is re
quire
d to
disc
lose
thos
e re
cord
s, u
nles
s th
ey c
an b
e la
wful
ly wi
thhe
ld u
nder
nin
e sp
ecific
exe
mpt
ions
out
lined
in th
e st
atut
e. T
he b
urde
n is
on th
e go
vern
men
t, no
t the
pub
lic, t
o pr
ovid
e ex
plan
atio
n fo
r why
info
rmat
ion
cann
ot b
e re
leas
ed.
• Th
e FO
IA M
anag
er p
ositio
n ha
s be
en fil
led
with
in th
e O
ffice
of R
ecor
ds, P
rivac
y an
d FO
IA.
• Th
e CF
PB is
alre
ady
rece
iving
and
re
spon
ding
to F
OIA
requ
ests
.
• FO
IA is
a k
ey c
ompo
nent
to th
e CF
PB b
eing
tran
spar
ent
with
the
publ
ic. It
has
a p
lan
in p
lace
that
it is
impl
emen
ting
to re
spon
d to
requ
ests
. The
laun
ch o
f the
eF
OIA
sys
tem
, whi
ch is
cur
rent
ly in
the
pilo
t pha
se, w
ill ex
ceed
wha
t the
law
requ
ires
of th
e CF
PB in
this
area
.
• In
our
judg
men
t, ba
sed
on th
e in
form
atio
n pr
ovid
ed, t
he
CFPB
has
met
its o
blig
atio
ns in
this
area
.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
79
Lega
l Req
uire
men
t De
mon
stra
ted
Perfo
rman
ce
Find
ing
/ Rec
omm
enda
tion
CFPB
is re
quire
d to
com
ply
with
the
E-G
over
nmen
t Act
of 2
002.
The
E-
Gov
ernm
ent A
ct o
f 200
2's p
urpo
se is
to im
prov
e el
ectro
nic
gove
rnm
ent
serv
ices
by e
stab
lishi
ng a
Fed
eral
Chi
ef T
echn
olog
y O
fficer
, loca
ted
in th
e O
ffice
of M
anag
emen
t and
Bud
get,
and
crea
ting
a fra
mew
ork
that
requ
ires
Inte
rnet
-bas
ed in
form
atio
n te
chno
logy
to im
prov
e th
e tra
nspa
renc
y of
and
ac
cess
to g
over
nmen
t info
rmat
ion
and
serv
ices
for c
itizen
s. T
he s
tatu
te
inclu
des
the
Fede
ral In
form
atio
n Se
curit
y M
anag
emen
t Act
of 2
002
(FIS
MA)
and
the
Conf
iden
tial In
form
atio
n Pr
otec
tion
and
Stat
istica
l Ef
ficie
ncy
Act (
CIPS
EA).
• Th
e CF
PB h
as d
evel
oped
and
impl
emen
ted
an IT
stru
ctur
e th
at a
dher
es to
the
E-G
over
nmen
t Act
, inclu
ding
FIS
MA.
• In
our
judg
men
t, ba
sed
on th
e in
form
atio
n pr
ovid
ed, t
he
CFPB
has
met
its o
blig
atio
ns in
this
area
.
CFPB
is re
quire
d to
com
ply
with
the
Fede
ral F
undi
ng a
nd A
ccou
ntab
ility
Tran
spar
ency
Act
(FFA
TA).
FFAT
A re
quire
s th
at a
ll ent
ities
or
orga
niza
tions
rece
iving
fede
ral fu
nds
as o
f FY
2007
are
disc
lose
d to
the
publ
ic, w
ith th
e in
tent
to e
mpo
wer a
ll citiz
ens
with
the
abilit
y to
hol
d th
e go
vern
men
t acc
ount
able
for s
pend
ing
decis
ions
. Al
l info
rmat
ion
on fe
dera
l aw
ards
are
ava
ilabl
e to
the
publ
ic via
www
.usa
spen
ding
.gov
, pro
vidin
g tra
nspa
rent
info
rmat
ion
to th
e pu
blic
on g
over
nmen
t spe
ndin
g de
cisio
ns.
• Th
e CF
PB p
osts
awa
rded
fede
ral c
ontra
cts
to its
web
site.
•
In o
ur ju
dgm
ent,
base
d on
the
info
rmat
ion
prov
ided
, the
CF
PB h
as m
et its
obl
igat
ions
in th
is ar
ea.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
80
Tab
le 1
7: A
chie
vem
ent
of O
rgan
izat
ion
al G
oals
(O
vera
ll S
trat
egie
s)
Org
aniz
atio
nal G
oal
Dem
onst
rate
d Pe
rform
ance
Fi
ndin
g / R
ecom
men
datio
n
Build
fam
iliarit
y wi
th th
e CF
PB b
rand
• La
stin
g br
and
fam
iliarit
y is
ofte
n ac
hiev
ed b
y go
ing
to w
here
peo
ple
are.
The
CF
PB h
as p
ositio
ned
itsel
f to
achi
eve
bran
d fa
milia
rity
by d
evel
opin
g a
good
we
b pr
esen
ce, b
uild
ing
rela
tions
hips
with
key
sta
keho
lder
s, s
truct
urin
g ke
y di
visio
ns in
the
man
ner m
ost a
cces
sible
to th
e CF
PB’s
key
audi
ence
(c
onsu
mer
s), a
nd u
sing
the
med
ia a
s a
vehi
cle to
rein
forc
e its
bra
nd.
• W
hile
the
CFPB
has
dem
onst
rate
d th
at a
gre
at d
eal o
f th
ough
t has
gon
e in
to its
bra
nd, o
ne c
once
rn is
that
the
CFPB
def
ines
its m
issio
n di
ffere
ntly
in d
iffere
nt p
lace
s.
And
while
it’s
unde
rsta
ndab
le to
a d
egre
e th
at th
e CF
PB w
ould
wan
t to
mak
e its
sta
ted
miss
ion
easy
to
unde
rsta
nd, s
trict
lang
uage
gui
delin
es p
erta
inin
g to
m
anda
te, m
issio
n, a
nd v
ision
will
help
bra
nd s
treng
th
over
time.
• Th
us, w
e re
com
men
d th
e CF
PB re
visit t
he th
ree
area
s it h
as p
ublic
ly co
mm
unica
ted
in p
rint it
s m
anda
te,
miss
ion,
visi
on a
nd v
alue
s an
d m
ake
effo
rts to
redu
ce
the
varia
nces
and
rem
ain
as c
onsis
tent
as
poss
ible
ac
ross
all m
ediu
ms.
Enga
ge th
e pu
blic
•
Mon
thly
even
ts o
utsid
e of
Was
hing
ton,
DC
to in
trodu
ce C
FPB
and
anno
unce
key
pol
icy d
elive
rabl
es w
ith a
n op
portu
nity
for f
eedb
ack
via
town
halls
, rou
ndta
bles
, wor
ksho
ps, e
tc.
• Th
e CF
PB h
as d
one
a gr
eat d
eal o
f wor
k to
eng
age
the
publ
ic an
d ha
s be
en c
reat
ive in
doi
ng s
o (s
omet
hing
not
ofte
n fo
und
in fe
dera
l age
ncie
s),
inclu
ding
by
sele
ctin
g ev
ent t
opics
bas
ed o
n im
porta
nt
date
s an
d iss
ues
so th
at th
ere
mig
ht b
e an
inhe
rent
pu
blic
inte
rest
in th
e to
pic
(i.e.
, less
ons
lear
ned
from
th
e fin
ancia
l cris
is –
Sept
embe
r 15)
.
Expl
ain
polic
y de
liver
able
s in
pla
in E
nglis
h
• Th
e we
bsite
was
dev
elop
ed w
ith a
n 8th
gra
de re
ader
in m
ind.
•
Gat
herin
g fe
edba
ck th
roug
h to
wn h
alls
and
cons
umer
eve
nts
allo
w th
e CF
PB to
“get
out
of t
he b
ubbl
e” a
nd d
eter
min
e wh
at c
onsu
mer
s ne
ed.
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce
elem
ent
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
81
Org
aniz
atio
nal G
oal
Dem
onst
rate
d Pe
rform
ance
Fi
ndin
g / R
ecom
men
datio
n
Illust
rate
the
cons
umer
impa
ct
• M
onth
ly ev
ents
like
thos
e di
scus
sed
abov
e ge
nera
te c
onsu
mer
sto
ries
that
he
lp ill
ustra
te th
e iss
ues
cons
umer
s ar
e fa
cing.
•
The
focu
s on
“poc
ketb
ook”
issu
es (i
ssue
s wi
th d
irect
rele
vanc
e to
the
ever
yday
lives
of A
mer
ican
fam
ilies
and
thei
r fin
ance
s) re
info
rce
that
the
CFPB
und
erst
ands
wha
t con
sum
ers
valu
e m
ost.
• Th
e in
clusio
n of
the
thre
e cr
iteria
that
poc
ketb
ook
polic
y de
liver
able
s ne
ed to
mee
t in o
rder
to m
axim
ize
natio
nal a
nd lo
cal a
ttent
ion
is an
exc
elle
nt s
trate
gy.
Also
a re
cent
op-
ed a
rticu
latin
g th
e im
pact
of t
he 9
0/10
ru
le in
the
for-p
rofit
educ
atio
n se
ctor
on
serv
icem
embe
rs is
a g
ood
exam
ple
of h
ow to
hig
hlig
ht
the
impa
ct o
f cer
tain
pol
icies
on
cons
umer
s.
• W
e re
com
men
d co
ntin
uing
to lo
ok fo
r cre
ative
way
s to
he
lp c
onsu
mer
s ex
pres
s th
e ch
alle
nges
they
face
and
th
eir p
erso
nal e
xper
ienc
es. D
oing
this
succ
essf
ully
will
be c
entra
l to th
e lo
ng-te
rm s
ucce
ss o
f the
CFP
B an
d wi
ll allo
w CF
PB to
dev
elop
fact
-bas
ed w
ays
to e
xpla
in
issue
s to
oth
er c
onsu
mer
s.
Max
imize
bur
eau
reso
urce
s
• W
hen
the
CFPB
con
vene
s ev
ents
aro
und
the
coun
try, it
see
ks to
take
ad
vant
age
of h
avin
g st
aff a
nd s
take
hold
ers
toge
ther
in th
at lo
catio
n (e
.g.,
arou
nd th
e Ph
ilade
lphi
a ev
ent o
n 9/
15, C
FPB
staf
f met
with
com
mun
ity
grou
ps fo
llowi
ng th
e pr
ess
even
t).
• In
divid
ual o
ffices
acr
oss
all d
ivisio
ns o
f CFP
B ar
e co
mm
itted
to w
orkin
g wi
th
othe
r tea
ms
and
help
ing
othe
r offic
es fu
lfill th
eir s
tatu
tory
out
reac
h m
anda
te
(e.g
., Co
mm
unity
Affa
irs p
rovid
ing
outre
ach
supp
ort a
t the
Phi
lade
lphi
a ev
ent o
n 9/
15).
• Th
e CF
PB h
as m
ade
a co
ncer
ted
effo
rt to
max
imize
re
sour
ces
and
acco
mpl
ished
a g
reat
dea
l with
limite
d st
aff in
par
t bec
ause
of it
s co
mm
itmen
t to
do s
o.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
82
Tab
le 1
8: A
chie
vem
ent
of O
rgan
izat
ion
al G
oals
(C
omm
uni
ty A
ffai
rs S
trat
egie
s)
Org
aniz
atio
nal G
oal
Dem
onst
rate
d Pe
rform
ance
Fi
ndin
g / R
ecom
men
datio
n
Touc
h m
ost s
igni
fican
t nat
iona
l and
regi
onal
con
sum
er, c
ivil r
ight
s, a
nd
gras
sroo
ts a
dvoc
acy
orga
niza
tions
in th
e fin
ancia
l ser
vices
spa
ce
(~20
0).
• O
ver t
he p
ast y
ear,
CFPB
has
hel
d ne
arly
250
mee
tings
wi
th g
roup
s in
cludi
ng A
ARP,
AFR
, You
th, N
CLR,
Lat
ino
grou
ps, N
AACP
, con
sum
er g
roup
s, c
ivil r
ight
s gr
oups
, fa
ith g
roup
s, e
tc.
• G
iven
how
signi
fican
t the
effo
rts h
ave
been
to
enga
ge c
omm
unity
gro
ups,
a tr
acke
r to
orga
nize
the
CFPB
’s ef
forts
in th
is ar
ea w
ill he
lp
it tel
l its
stor
y of
who
it is
reac
hing
and
how
it is
reac
hing
them
. The
trac
ker c
ould
inclu
de a
list
of g
roup
s th
e CF
PB h
as e
ngag
ed, t
he la
st p
oint
of
con
tact
, nat
ure
of th
e co
ntac
t, ne
xt s
teps
to
furth
er e
ngag
e th
e or
gani
zatio
n, a
nd p
erha
ps
som
e as
sess
men
t of t
he d
egre
e to
whi
ch th
at
orga
niza
tion
is cu
rrent
ly en
gage
d.
Deve
lop
“ear
ly wa
rnin
g” in
form
atio
n fro
m th
e fie
ld a
nd m
ake
avai
labl
e to
al
l CFP
B re
ports
and
stu
dies
from
con
sum
er, c
ivil r
ight
s, a
nd c
omm
unity
gr
oups
abo
ut im
pact
s of
spe
cific
finan
cial s
ervic
e pr
oduc
ts a
nd p
ract
ices
on n
eigh
borh
oods
and
com
mun
ities.
• Th
e m
eetin
gs m
entio
ned
abov
e as
wel
l as
roun
dtab
le
disc
ussio
ns th
e CF
PB h
olds
, ofte
n in
con
junc
tion
with
a
larg
er C
FPB-
host
ed e
vent
(e.g
., Ph
ilade
lphi
a on
9/1
5/11
) se
rve
as p
roac
tive
solic
itatio
ns fo
r fee
dbac
k fro
m th
e “fi
eld”
. In
addi
tion,
the
rela
tions
hips
dev
elop
ed w
ith th
e gr
oups
out
lined
abo
ve c
reat
e a
feed
back
loop
so
that
th
ose
grou
ps h
ave
acce
ss to
the
CFPB
to s
hare
in
form
atio
n.
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce e
lem
ent
Crea
te s
earc
habl
e co
nten
t res
ourc
e of
thos
e re
ports
and
stu
dies
, and
pr
ovid
e pe
riodi
c up
date
s fo
r all C
FPB
staf
f of t
he in
put r
ecei
ved
from
th
ese
grou
ps.
• W
hile
the
CFPB
is in
the
proc
ess
of d
evel
opin
g th
e se
arch
able
con
tent
reso
urce
, as
soon
as
Cons
umer
Af
fairs
get
s re
ports
(int
erna
l and
ext
erna
l), th
ey s
hare
ex
cerp
ts a
nd k
ey p
oint
s wi
th o
ther
CFP
B st
aff.
• Th
e co
mpl
ete
deve
lopm
ent o
f a s
earc
habl
e co
nten
t res
ourc
e wi
ll be
a te
rrific
way
to s
hare
in
form
atio
n an
d m
axim
ize b
urea
u re
sour
ces.
Be a
reso
urce
to c
onsu
mer
, civi
l rig
hts
and
nonp
rofit
orga
niza
tions
, and
he
lp a
ll par
ts o
f the
CFP
B ac
cess
kno
wled
ge a
nd in
form
atio
n fro
m th
ose
grou
ps.
• Ro
undt
able
s he
ld b
y th
e CF
PB b
ring
toge
ther
co
nstitu
ency
gro
ups,
inclu
ding
old
er A
mer
icans
, stu
dent
s an
d m
inor
ity g
roup
s to
cre
ate
a tw
o-wa
y di
alog
ue.
• An
inte
rnal
wee
kly lo
ok-a
-hea
d do
cum
ent is
pro
vided
to
all C
FPB
pers
onne
l so
they
can
see
upc
omin
g ex
tern
al
mee
tings
takin
g pl
ace
in th
e ev
ent it
mak
es s
ense
for
othe
r gro
ups
with
in C
FPB
to p
artic
ipat
e.
• Ad
ditio
nal r
esou
rces
inclu
de: s
ocia
l med
ia, t
he w
ebsit
e an
d th
e 80
0 nu
mbe
r.
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce e
lem
ent
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
83
Tab
le 1
9: A
chie
vem
ent
of O
rgan
izat
ion
al G
oals
(A
nec
dot
al G
oals
)
Org
aniz
atio
nal G
oal
Dem
onst
rate
d Pe
rform
ance
Fi
ndin
g / R
ecom
men
datio
n
Adhe
re to
all a
ppro
pria
te fe
dera
l man
date
s
• Th
e CF
PB a
dher
es to
the
Dodd
-Fra
nk A
ct, F
OIA
, FF
ATA,
and
the
e-G
over
nmen
t Act
.
• In
our
judg
men
t, ba
sed
on th
e in
form
atio
n pr
ovid
ed, t
he C
FPB
has
met
its o
blig
atio
ns in
th
is ar
ea. A
s m
entio
ned
in T
able
18,
whi
le th
e ro
le o
f the
Om
buds
man
is fil
led
with
a d
etai
lee,
it do
es n
ot h
ave
a fu
ll-tim
e pe
rman
ent e
mpl
oyee
fill
ing
the
posit
ion.
We
reco
mm
end
doin
g so
as
soon
as
poss
ible
.
Mai
ntai
n th
e sp
irit o
f tra
nspa
renc
y th
at w
as “b
aked
into
the
orga
niza
tion”
at
its in
cept
ion
• Th
e CF
PB m
ade
both
Eliz
abet
h W
arre
n an
d Ra
j Dat
e’s
sche
dule
pub
lic o
n th
e we
bsite
. •
The
CFPB
has
a p
roac
tive,
forw
ard-
look
ing
FOIA
op
erat
ion
in p
lace
. •
Ever
yone
we
inte
rvie
wed
took
tran
spar
ency
and
ac
coun
tabi
lity v
ery
serio
usly.
• W
e re
com
men
d th
e CF
PB c
ontin
ue its
effo
rts
arou
nd tr
ansp
aren
cy a
nd c
ontin
ue to
find
new
ways
to d
emon
stra
te its
com
mitm
ent in
this
area
. Ide
as in
clude
: mak
ing
agen
das
and
min
utes
from
pub
lic a
nd in
tern
al m
eetin
gs
avai
labl
e.
Educ
ate
the
publ
ic on
wha
t CFP
B is
and
what
it is
doin
g to
hel
p or
dina
ry
Amer
icans
• Th
e CF
PB c
reat
ed a
web
site
that
is e
asy
to n
avig
ate
and
unde
rsta
nd a
nd u
ses
it as
a ve
hicle
to e
ngag
e co
nsum
ers,
inclu
ding
see
king
and
impl
emen
ting
thei
r fe
edba
ck.
• Th
e CF
PB h
as m
ade
a co
ncer
ted
effo
rt to
go
to w
here
th
e pu
blic
is by
cre
atin
g th
e O
ffice
of E
ngag
emen
t and
ho
ldin
g ev
ents
with
con
sum
er g
roup
s ac
ross
the
coun
try.
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce e
lem
ent
Mee
t with
com
mun
ity b
anke
rs fr
om a
ll 50
stat
es
• Th
e CF
PB a
chie
ved
this
goal
ahe
ad o
f sch
edul
e.
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce e
lem
ent
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
84
Tab
le 2
0: A
chie
vem
ent
of O
rgan
izat
ion
al G
oals
(C
onsu
mer
En
gage
men
t)
Org
aniz
atio
nal G
oal
Dem
onst
rate
d Pe
rform
ance
Fi
ndin
g / R
ecom
men
datio
n
CFPB
-wid
e sh
ared
visi
on o
f the
role
of
enga
gem
ent a
nd th
e de
sired
impa
ct o
n th
e pu
blic
of o
ur e
ngag
emen
t wor
k
• CE
E ha
s m
et w
ith a
ll of it
s in
tern
al d
ivisio
ns (i
.e.,
Cons
umer
Eng
agem
ent,
OSA
, etc
.), a
nd m
any
publ
ic-fa
cing
divis
ions
, (i.e
., Ex
tern
al A
ffairs
, Med
ia
Rela
tions
), to
cre
ate
a sh
ared
visi
on a
s se
rvice
pro
vider
s fo
r dig
ital a
nd n
on-
digi
tal e
ngag
emen
t cam
paig
ns a
cros
s th
e CF
PB.
• CE
E ha
s al
so m
et w
ith C
FPB
lead
ersh
ip to
disc
uss
a go
vern
ance
stru
ctur
e fo
r th
e CF
PB’s
curre
nt d
igita
l offe
rings
and
wor
k on
long
-term
visi
ons
for t
he
offe
rings
. •
Two
work
ing
sess
ions
hav
e ta
ken
plac
e to
def
ine
CEE’
s m
issio
n an
d vis
ion;
to
date
, a d
raft
miss
ion
has
been
dev
elop
ed.
• Co
nsum
er E
ngag
emen
t sho
uld
cont
inue
to
work
on
defin
ing
its o
wn m
issio
n an
d vis
ion,
en
surin
g th
at th
ey a
re in
agr
eem
ent w
ith th
e m
issio
n an
d vis
ion
of th
e CF
PB a
s a
whol
e.
Deve
lopi
ng s
pecif
ic ob
ject
ives
for e
ach
offic
e wi
thin
the
CFPB
mak
es s
ense
, but
it is
very
im
porta
nt th
at th
ose
obje
ctive
s al
ign
with
the
over
all m
issio
n of
the
CFPB
.
Org
aniza
tiona
l stru
ctur
e, p
ositio
n de
scrip
tions
, ca
reer
ladd
ers,
recr
uitm
ent p
lan,
and
pol
icies
to
supp
ort t
he w
ork
(exa
mpl
e, “b
log
on o
ther
site
s”
polic
y)
• CE
E ha
s fo
cuse
d its
effo
rts o
n de
velo
ping
cur
rent
per
sonn
el in
Con
sum
er
Enga
gem
ent a
nd d
oubl
ing
the
size
of th
e of
fice
(exc
ludi
ng le
ader
ship
) fro
m
two
to fo
ur b
y 2Q
201
2.
• Po
sitio
n de
scrip
tions
and
car
eer l
adde
rs fo
r the
se n
ew p
ositio
ns a
re e
ither
in
plac
e or
in d
evel
opm
ent.
• CE
E ha
s de
cided
to d
efer
furth
er re
crui
ting
effo
rts u
ntil 2
Q 2
012
in o
rder
to
take
adv
anta
ge o
f a b
ette
r-exp
ecte
d re
crui
ting
envir
onm
ent.
• CE
E ha
s id
entifi
ed a
num
ber o
f are
as o
f dev
elop
men
t tha
t dee
m d
iscus
sion,
th
ough
no
subs
tant
ive d
evel
opm
ent h
as ta
ken
plac
e ye
t. •
The
orga
niza
tiona
l cha
rt ha
s un
derg
one
a nu
mbe
r of e
dits
sin
ce J
uly,
with
ap
prop
riate
cha
nges
with
in C
EE re
flect
ed.
• Co
nsum
er E
ngag
emen
t sho
uld
mov
e qu
ickly
to
fill o
ut th
e of
fice
and
deve
lop
the
appr
opria
te
plan
s an
d po
licie
s to
allo
w it t
o ef
fect
ively
oper
ate.
Blue
prin
t for
the
CFPB
“con
sum
er e
xper
ienc
e,”
conc
epts
for C
FPB
prod
uct a
nd s
ervic
e of
ferin
gs
such
as
inte
ract
ive to
ols,
plu
s pl
an w
ith tim
elin
e to
br
ing
one
or m
ore
of th
ose
mor
e sig
nific
ant t
ools
to
fruitio
n
• Co
nsum
er E
ngag
emen
t is w
orkin
g wi
th a
n ou
tsid
e co
ntra
ctor
to d
evel
op a
dr
aft b
luep
rint f
or th
e CF
PB c
onsu
mer
exp
erie
nce;
the
blue
prin
t will
be
pres
ente
d to
CFP
B le
ader
ship
the
week
of O
ctob
er 1
0th.
• Fi
nal s
ign-
off is
exp
ecte
d in
mid
-Nov
embe
r, on
trac
k fo
r a fin
al d
elive
ry o
f De
cem
ber 2
011.
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce e
lem
ent
IT s
olut
ion
for e
dito
rial w
orkf
low
and
cont
ent
man
agem
ent s
yste
m fo
r Con
sum
erFi
nanc
e.go
v
• Co
nsum
er E
ngag
emen
t has
col
labo
rate
d wi
th C
FPB’
s te
chno
logy
and
in
form
atio
n of
fices
and
requ
este
d th
e ne
cess
ary
budg
et a
nd p
erso
nnel
for t
his
proj
ect.
• Co
nsum
er E
ngag
emen
t exp
ects
this
proj
ect t
o be
gin
durin
g 2Q
201
2, th
ough
di
scus
sions
are
alre
ady
unde
rway
to d
eter
min
e th
e pr
ojec
t’s s
cope
, re
quire
men
ts a
nd tim
elin
e.
• W
e re
com
men
d Co
nsum
er E
ngag
emen
t co
ntin
ue to
wor
k th
e te
chno
logy
and
info
rmat
ion
offic
es w
ithin
CFP
B to
dev
elop
the
scop
e,
requ
irem
ents
and
timel
ine
of th
e pr
ojec
t.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
85
Org
aniz
atio
nal G
oal
Dem
onst
rate
d Pe
rform
ance
Fi
ndin
g / R
ecom
men
datio
n
Impr
oved
bus
ines
s pr
oces
s fo
r gen
erat
ing
and
clear
ing
cont
ent f
or u
se o
n ou
r web
site
and
othe
r el
ectro
nic
chan
nels
• Du
e to
the
CFPB
-wid
e st
rate
gy p
roce
ss, w
hich
has
iden
tified
the
clear
ance
pr
oces
s as
a p
ossib
le a
rea
for i
mpr
ovem
ent,
Cons
umer
Eng
agem
ent h
as
defe
rred
work
on
an im
prov
ed b
usin
ess
proc
ess
for g
ener
atin
g an
d cle
arin
g co
nten
t for
web
site
and
elec
troni
c us
e.
• If
the
clear
ance
pro
cess
is d
eter
min
ed a
s an
are
a fo
r im
prov
emen
t, Co
nsum
er
Enga
gem
ent p
lans
to in
volve
itsel
f in th
e ne
w po
licy
deve
lopm
ent p
roce
ss.
• If
the
clear
ance
pro
cess
is no
t det
erm
ined
as
an a
rea
for i
mpr
ovem
ent,
the
Cons
umer
Eng
agem
ent w
ill m
ove
forw
ard
with
impr
ovin
g th
e pr
oces
s al
read
y in
pla
ce.
• If
it is
dete
rmin
ed th
at th
e Cl
eara
nce
Proc
ess
is in
nee
d of
impr
ovem
ent,
we re
com
men
d co
nsid
erat
ions
for a
mor
e st
ream
lined
app
roac
h an
d st
rong
ly en
cour
age
Cons
umer
En
gage
men
t to
be in
volve
d in
the
proc
ess
of
deve
lopi
ng a
new
pol
icy.
8-10
blo
g po
sts
each
mon
th g
ener
ated
by
the
Enga
gem
ent O
ffice,
plu
s su
ppor
t for
finan
cial
educ
atio
n co
nten
t in p
ost a
nd tip
form
gen
erat
ed b
y th
e O
FE (i
n ad
ditio
n to
pos
ts fr
om a
roun
d th
e bu
reau
)
• Co
nsum
er E
ngag
emen
t has
con
siste
ntly
work
ed w
ith a
num
ber o
f oth
er
offic
es, in
cludi
ng C
omm
unity
Affa
irs a
nd O
SA, t
o hi
ghlig
ht in
tera
ctio
ns w
ith th
e pu
blic
and
stak
ehol
der g
roup
s on
the
CFPB
blo
g.
• CE
E is
begi
nnin
g a
pilo
t pro
gram
to p
rodu
ce 2
to 3
blo
g po
sts
a we
ek a
roun
d a
“CFP
B in
you
r com
mun
ity th
eme,
” whi
ch w
ill fe
atur
e re
ad-o
uts
and
copi
es o
f pr
epar
ed re
mar
ks o
f sen
ior C
FPB
offic
ials
mee
ting
with
ext
erna
l sta
keho
lder
s (i.
e., c
omm
unity
and
indu
stry
gro
ups)
aro
und
the
coun
try.
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce e
lem
ent
Cons
isten
t pro
mot
ion
of o
ur m
oney
edu
catio
n co
nten
t suc
h as
tip o
f the
day
to o
ther
sit
es/c
hann
els
• W
hile
Con
sum
er E
ngag
emen
t is w
orkin
g in
col
labo
ratio
n wi
th th
e O
ffice
of
Fina
ncia
l Edu
catio
n to
pla
n fo
r pos
ting,
pro
mot
ing
and
dist
ribut
ing
this
cont
ent
as s
oon
as it
is av
aila
ble
for p
ublic
atio
n, s
ome
of th
is wo
rk w
ill be
dep
ende
nt
on th
e de
velo
pmen
t of t
he b
luep
rint m
entio
ned
abov
e.
• W
e re
com
men
d Co
nsum
er E
ngag
emen
t co
ntin
ue to
pla
n fo
r the
pro
mot
ion
of e
duca
tion
cont
ent t
o en
sure
pro
mot
ion
is as
sea
mle
ss a
s po
ssib
le o
nce
it is
read
y fo
r pub
licat
ion.
Web
por
tals
for t
he e
mpo
werm
ent o
ffices
plu
s O
FE
(My
Fi) a
nd F
air L
endi
ng
• Th
e of
fice
of F
air L
endi
ng a
nd E
qual
Opp
ortu
nity
’s we
b po
rtal a
nd a
n im
prov
ed
site
for t
he O
ffice
of C
omm
unity
Ban
ks a
nd C
redi
t Uni
ons
is se
t to
laun
ch th
e we
ek o
f Oct
ober
2nd
. •
The
web
porta
l for O
SA is
sch
edul
ed to
laun
ch la
ter i
n O
ctob
er.
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce e
lem
ent
One
to tw
o in
itial o
fferin
gs to
eng
age
the
publ
ic on
m
oney
issu
es o
r mon
ey d
ecisi
on-m
akin
g in
clo
se
coop
erat
ion
with
OFE
•
This
work
is d
epen
dent
on
the
cons
umer
exp
erie
nce
blue
prin
t des
crib
ed
abov
e.
• W
e re
com
men
d CF
PB m
ove
forw
ard
with
pla
ns
for t
he c
onsu
mer
exp
erie
nce
blue
prin
t for
de
liver
y in
Dec
embe
r 201
1.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
86
Org
aniz
atio
nal G
oal
Dem
onst
rate
d Pe
rform
ance
Fi
ndin
g / R
ecom
men
datio
n
Desig
n an
d im
plem
enta
tion
of c
alen
dar f
or u
se o
f di
rect
em
ail to
ol
• Du
e to
the
CFPB
-wid
e st
rate
gy p
roce
ss in
pla
ce, it
was
det
erm
ined
that
an
inte
rim d
irect
mai
l stra
tegy
wou
ld b
e im
plem
ente
d un
til co
mpl
etio
n of
the
CFPB
-wid
e pr
oces
s wa
s co
mpl
ete.
•
Cons
umer
Eng
agem
ent le
d a
cros
s-di
visio
nal e
ffort
to d
evel
op th
e in
terim
ed
itoria
l cal
enda
r and
stra
tegy
for b
uild
ing
list s
egm
ents
(e.g
., a
targ
eted
list o
f sm
all fi
nanc
ial s
ervic
es p
rovid
ers)
that
was
put
in p
lace
in S
epte
mbe
r. •
Cons
umer
Eng
agem
ent w
ill be
hea
vily
invo
lved
in d
evel
opm
ent o
f a lo
nger
-te
rm s
trate
gy th
at w
ill fo
llow
the
final
CFP
B-wi
de o
rgan
izatio
nal s
trate
gy.
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce e
lem
ent
Web
stre
amin
g ca
pacit
y (fo
r Oct
OSA
con
veni
ng,
enfo
rcem
ent h
earin
gs)
• Co
nsum
er E
ngag
emen
t coo
rdin
ated
with
CFP
B te
chno
logy
and
info
rmat
ion
offic
es to
suc
cess
fully
stre
am R
aj D
ate’
s Ph
ilade
lphi
a sp
eech
on
9/15
/201
1.
• Th
ere
are
plan
s to
live
stre
am tw
o m
ore
CFPB
eve
nts
this
mon
th.
• W
e en
cour
age
CFPB
to c
ontin
ue to
use
live
stre
amin
g as
a c
omm
unica
tions
tool
, as
it allo
ws
thos
e wh
o ar
e un
able
to a
ttend
CFP
B ev
ents
th
e op
portu
nity
to b
e a
part
of th
em.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
87
Tab
le 2
1: A
chie
vem
ent
of O
rgan
izat
ion
al G
oals
(S
ervi
cem
emb
er A
ffai
rs)
Org
aniz
atio
nal G
oal
Dem
onst
rate
d Pe
rform
ance
Fi
ndin
g / R
ecom
men
datio
n
Deve
lop
milit
ary
cont
ent f
or w
ebsit
e/so
cial m
edia
• O
SA h
as d
evel
oped
num
erou
s so
urce
s of
web
con
tent
, inclu
ding
a
spec
ific la
ndin
g pa
ge o
n th
e CF
PB w
ebsit
e fo
r ser
vicem
embe
rs th
at
high
light
s wh
o O
SA is
and
wha
t the
y ar
e do
ing
for m
embe
rs o
f the
m
ilitar
y an
d th
eir f
amilie
s, a
nd n
umer
ous
blog
pos
ts a
nd a
rticle
s re
gard
ing
the
happ
enin
gs in
side
OSA
and
the
even
ts, s
peec
hes,
et
c. th
at H
olly
Petra
eus
has
parti
cipat
ed in
.
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce
elem
ent
Host
con
veni
ng in
Oct
ober
con
cern
ing
best
pr
actic
es in
offe
ring
finan
cial p
rodu
cts
to m
ilitar
y
• A
Requ
est f
or In
form
atio
n wa
s re
leas
ed in
the
Fede
ral R
egist
er o
n Se
ptem
ber 6
, 201
1 fo
r inf
orm
atio
n on
the
prod
ucts
and
ser
vices
that
ar
e un
ique
to s
ervic
emem
bers
and
thei
r fam
ilies.
The
Req
uest
for
Info
rmat
ion
was
diss
emin
ated
thro
ugh
all m
edia
and
dist
ribut
ion
chan
nels.
•
The
orig
inal
Oct
ober
con
veni
ng d
ate
was
mov
ed to
Nov
embe
r 8,
2011
in a
n ef
fort
to a
void
logi
stica
l con
flicts
with
Stu
dent
and
Old
er
Amer
ican
rollo
ut e
vent
s.
• O
SA is
in fu
ll pla
nnin
g m
ode
for t
he c
onve
ning
, put
ting
toge
ther
pa
nels,
que
stio
n se
ts a
nd fig
urin
g ou
t logi
stics
. Ho
weve
r, be
caus
e of
a c
onflic
t with
Pre
siden
t Oba
ma’
s Fi
nanc
ial E
duca
tion
Sum
mit,
OSA
’s co
nven
ing
may
be
mov
ed a
gain
.
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce
elem
ent
Eval
uate
finan
cial e
duca
tion
at m
ilitar
y ba
sic
train
ing
• M
embe
rs o
f OSA
hav
e vis
ited
basic
trai
ning
site
s of
two
milit
ary
divis
ions
: the
Nav
y an
d M
arin
e Co
rps.
•
OSA
is s
ched
uled
to v
isit t
he b
asic
train
ing
site
for t
he A
rmy
at F
ort
Jack
son
on N
ovem
ber 4
, 201
1.
• Vi
sits
to th
e Ai
r For
ce a
nd C
oast
Gua
rd b
asic
train
ing
sites
are
cu
rrent
ly be
ing
sche
dule
d.
• So
far,
OSA
has
mad
e on
ly in
itial o
bser
vatio
ns, b
ut w
ants
to fo
cus
on th
e be
ginn
ing
of m
ilitar
y ca
reer
s an
d th
e us
e of
tech
nolo
gy to
m
oder
nize
finan
cial e
duca
tion
for n
ew m
embe
rs o
f the
milit
ary.
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce
elem
ent
Deve
lop
revis
ed c
urric
ulum
for n
ew re
crui
ts in
co
ordi
natio
n wi
th th
e De
partm
ent o
f Def
ense
(D
oD)
• Th
e de
velo
pmen
t of r
evise
d cu
rricu
lum
for n
ew re
crui
ts is
und
erwa
y wi
th D
oD; O
SA is
in a
dat
a-ga
ther
ing
phas
e.
• In
itial o
bser
vatio
ns s
how
a va
rianc
e am
ong
curri
culu
ms
acro
ss
milit
ary
divis
ions
.
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce
elem
ent
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
88
Org
aniz
atio
nal G
oal
Dem
onst
rate
d Pe
rform
ance
Fi
ndin
g / R
ecom
men
datio
n
Prov
ide
milit
ary
expe
rtise
for C
onsu
mer
Re
spon
se: s
crip
ts, F
AQs,
refe
rrals,
tailo
red
assis
tanc
e
• Al
l Con
sum
er R
espo
nse
scrip
ts, F
AQs,
refe
rrals,
and
tailo
red
assis
tanc
e wi
th re
spec
t to
serv
icem
embe
rs h
ave
been
dev
elop
ed
with
ext
ensiv
e O
SA in
put.
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce
elem
ent
Raise
awa
rene
ss o
f CFP
B/O
SA th
roug
h m
edia
, sp
eech
es a
nd o
utre
ach
to b
usin
ess
and
gove
rnm
ent
• CF
PB a
nd O
SA h
ave
both
ext
ensiv
ely
used
CFP
B’s
blog
to
diss
emin
ate
info
rmat
ion
rega
rdin
g th
e go
ings
on
in th
e bu
reau
as
a wh
ole
and
OSA
. Bo
th h
ave
used
the
blog
to in
form
the
publ
ic on
sp
eech
es a
nd e
vent
s th
at h
ave
take
n pl
ace,
as
well a
s as
ked
for
the
publ
ic’s
inpu
t on
mul
tiple
issu
es.
• Ho
lly P
etra
eus
has
give
n 22
spe
eche
s sin
ce h
er a
ppoi
ntm
ent a
s Di
rect
or o
f OSA
in J
anua
ry 2
011.
Exa
mpl
es o
f gro
ups
she
has
spok
en to
inclu
de w
ound
ed s
oldi
ers
at W
alte
r Ree
d Na
tiona
l Milit
ary
Med
ical C
ente
r, th
e As
socia
tion
of M
ilitar
y Ba
nks,
the
Arm
y JA
G
Scho
ol, t
he W
ound
ed W
arrio
rs p
roje
ct, a
nd m
embe
rs o
f the
U.S
. Ho
use
and
Sena
te.
• M
embe
rs o
f the
OSA
team
hav
e he
ld n
umer
ous
town
halls
and
ro
undt
able
s an
d tra
vele
d to
milit
ary
base
s ac
ross
the
coun
try to
cr
eate
a fe
edba
ck lo
op th
roug
h wh
ich O
SA c
an e
duca
te m
embe
rs
of th
e m
ilitar
y on
wha
t is g
oing
on
insid
e th
e of
fice
and
OSA
can
le
arn
from
milit
ary
mem
bers
wha
t issu
es a
re th
e m
ost im
porta
nt to
th
em.
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce
elem
ent
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
89
Tab
le 2
2: A
lign
men
t w
ith
Per
form
ance
Sta
nd
ard
s (G
oals
an
d O
bje
ctiv
es)
Goa
l Sc
ore
Sum
mar
y of
Per
form
ance
Pr
iorit
y F
indi
ng /
Reco
mm
enda
tion
Build
fam
iliarit
y wi
th th
e CF
PB
bran
d
Build
ing
bran
d aw
aren
ess
take
s tim
e. T
he C
FPB
has
esta
blish
ed a
sol
id fo
unda
tion
for a
chie
ving
fam
iliarit
y am
ong
“eve
ryda
y Am
erica
ns” a
nd h
as h
ad a
stro
ng in
tere
st fr
om
cons
umer
s gi
ven
its s
hort
life s
pan.
How
ever
, its
work
in th
is ar
ea is
onl
y be
ginn
ing
to a
chie
ve its
goa
ls an
d m
inor
in
cons
isten
cies
in th
e us
e of
bra
nd-re
late
d la
ngua
ge c
ould
slo
w aw
aren
ess.
Low
• W
e re
com
men
d th
e CF
PB re
visit t
he th
ree
area
s it h
as
publ
icly
com
mun
icate
d in
prin
t its
man
date
, miss
ion,
visi
on
and
valu
es a
nd m
ake
effo
rts to
redu
ce th
e va
rianc
es a
nd
rem
ain
as c
onsis
tent
as
poss
ible
acr
oss
all m
ediu
ms.
•
Spec
ifical
ly, d
iscon
tinue
usin
g th
e “M
issio
n” la
ngua
ge a
s it’s
du
plica
tive
of th
e St
atut
ory
Purp
ose
and
Obj
ectiv
es (b
oth
of
which
use
lang
uage
that
is c
lear
and
sui
tabl
e fo
r con
sum
er
facin
g co
mm
unica
tion)
, kee
p th
e vis
ion
and
use
it as
a pa
rt of
the
lang
uage
on
the
webs
ite a
nd in
con
sum
er fa
cing
vehi
cles
as p
art o
f a s
ectio
n de
vote
d to
“wha
t doe
s th
is m
ean
for y
ou”.
Enga
ge th
e pu
blic
The
CFPB
is e
mph
asizi
ng th
is ar
ea a
nd u
nder
stan
dabl
y so
gi
ven
that
suc
cess
ful e
ngag
emen
t of t
he p
ublic
can
hel
p it
achi
eve
othe
r goa
ls in
cludi
ng b
rand
fam
iliarit
y an
d illu
stra
tion
of c
onsu
mer
impa
ct.
CFPB
has
mad
e a
cons
cious
effo
rt to
en
gage
with
the
publ
ic th
roug
h its
web
site
and
blog
, as
well a
s us
ing
thos
e pl
atfo
rms
for s
olici
ting
publ
ic fe
edba
ck o
n CF
PB
initia
tives
(e.g
., Re
ques
t for
Com
men
t issu
ed fo
r “la
rger
pa
rticip
ant”
defin
ition,
and
Kno
w Be
fore
You
Owe
feed
back
).
High
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Expl
ain
polic
y de
liver
able
s in
pl
ain
Engl
ish
The
webs
ite is
the
prim
ary
exte
rnal
com
mun
icatio
ns to
ol fo
r th
e CF
PB to
reac
h th
e co
nsum
er a
nd it
has
set t
he to
ne fo
r co
mm
unica
ting
in “p
lain
Eng
lish”
. CF
PB h
as m
ade
a co
ncer
ted
effo
rt to
tran
slate
com
plex
finan
cial la
ngua
ge in
to
lang
uage
that
any
one
coul
d un
ders
tand
, inclu
ding
dev
elop
ing
and
mai
ntai
ning
the
cont
ent o
f the
CFP
B’s
webs
ite a
t an
8th
grad
e re
adin
g le
vel.
Med
ium
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
90
Goa
l Sc
ore
Sum
mar
y of
Per
form
ance
Pr
iorit
y F
indi
ng /
Reco
mm
enda
tion
Illust
rate
the
cons
umer
impa
ct
Brin
ging
the
stor
ies
of h
ow th
e co
nsum
er is
impa
cted
is th
e m
issio
n of
the
depa
rtmen
t of C
onsu
mer
Eng
agem
ent a
nd
Educ
atio
n. T
he C
FPB
has
also
aim
ed to
use
“hum
an fa
ces”
of
the
bure
au to
com
mun
icate
impa
ct to
con
sum
ers.
For
ex
ampl
e, th
e CF
PB a
ppoi
nted
Hol
ly Pe
traeu
s as
the
Dire
ctor
of
the
Offic
e of
Ser
vicem
embe
r Affa
irs, w
ho a
s th
e wi
fe a
nd
mot
her o
f ser
vicem
embe
rs h
as a
uni
que
know
ledg
e an
d un
ders
tand
ing
of th
e liv
es o
f ser
vicem
embe
rs.
Mrs
. Pet
raeu
s’ Ne
w Yo
rk Tim
es o
p-ed
in S
epte
mbe
r 201
1 on
how
for-p
rofit
scho
ols
are
takin
g ad
vant
age
of s
ervic
emem
bers
and
thei
r fa
milie
s fu
rther
dem
onst
rate
s he
r uni
que
and
appr
opria
te
know
ledg
e ba
se.
CFPB
has
also
use
d a
Tel
l You
r Sto
ry
stra
tegy
to d
emon
stra
te re
al c
onsu
mer
sto
ries
to th
e pu
blic.
High
•
We
reco
mm
end
the
CFPB
con
tinue
to fin
d wa
ys to
hig
hlig
ht
othe
r fac
es w
ithin
the
bure
au a
s it g
rows
and
mat
ures
.
Max
imize
bur
eau
reso
urce
s
The
CFPB
’s de
term
inat
ion
to n
ot le
t lim
ited
staf
f be
an e
xcus
e is
appr
ecia
ble.
It h
as m
ade
the
mos
t of t
he re
sour
ces
it has
an
d ha
s m
ade
a co
nscio
us e
ffort
to e
ngag
e di
ffere
nt m
embe
rs
of d
iffere
nt te
ams
acro
ss th
e or
gani
zatio
n to
max
imize
resu
lts.
(e.g
., th
e ov
erla
ppin
g of
the
Cons
umer
Eng
agem
ent,
Com
mun
ity A
ffairs
and
Med
ia R
elat
ions
team
s).
Med
ium
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Touc
h m
ost s
igni
fican
t na
tiona
l and
regi
onal
co
nsum
er, c
ivil r
ight
s, a
nd
gras
sroo
ts a
dvoc
acy
orga
niza
tions
in th
e fin
ancia
l se
rvice
s sp
ace
(~20
0).
Ove
r the
pas
t yea
r, CF
PB h
as h
eld
near
ly 25
0 m
eetin
gs w
ith
grou
ps in
cludi
ng A
ARP,
AFR
, You
th, N
CLR,
Lat
ino
grou
ps,
NAAC
P, c
onsu
mer
gro
ups,
civi
l rig
hts
grou
ps, f
aith
gro
ups,
et
c.
High
• G
iven
how
signi
fican
t the
effo
rts h
ave
been
to e
ngag
e co
mm
unity
gro
ups,
a tr
acke
r to
orga
nize
the
CFPB
’s ef
forts
in
this
area
will
help
it te
ll its
sto
ry o
f who
it’s
reac
hing
and
ho
w it’s
reac
hing
them
. The
trac
ker c
ould
inclu
de a
list o
f gr
oups
the
CFPB
has
eng
aged
, the
last
poi
nt o
f con
tact
, na
ture
of t
he c
onta
ct, n
ext s
teps
to fu
rther
eng
agin
g th
e or
gani
zatio
n an
d pe
rhap
s so
me
asse
ssm
ent o
f the
deg
ree
to w
hich
that
org
aniza
tion
is cu
rrent
ly en
gage
d.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
91
Goa
l Sc
ore
Sum
mar
y of
Per
form
ance
Pr
iorit
y F
indi
ng /
Reco
mm
enda
tion
Deve
lop
“ear
ly wa
rnin
g”
info
rmat
ion
from
the
field
and
m
ake
avai
labl
e to
all C
FPB
repo
rts a
nd s
tudi
es fr
om
cons
umer
, civi
l rig
hts,
and
co
mm
unity
gro
ups
abou
t im
pact
s of
spe
cific
finan
cial
serv
ice p
rodu
cts
and
prac
tices
on
neig
hbor
hood
s an
d co
mm
unitie
s.
The
mee
tings
men
tione
d ab
ove
as w
ell a
s th
e ro
undt
able
di
scus
sion
s th
e C
FPB
hold
s—of
ten
in c
onju
nctio
n w
ith a
la
rger
CFP
B-ho
sted
eve
nt in
a c
ity (e
.g.,
Phila
delp
hia
on
9/15
/11)
—se
rve
as p
roac
tive
solic
itatio
ns fo
r fee
dbac
k fro
m th
e “fi
eld”
. In
addi
tion,
the
rela
tions
hips
dev
elop
ed
with
the
grou
ps o
utlin
ed a
bove
cre
ate
a fe
edba
ck lo
op s
o th
at th
ose
grou
ps h
ave
acce
ss to
the
CFP
B to
sha
re
info
rmat
ion.
Low
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce e
lem
ent
Crea
te s
earc
habl
e co
nten
t re
sour
ce o
f tho
se re
ports
and
st
udie
s, a
nd p
rovid
e pe
riodi
c up
date
s fo
r all C
FPB
staf
f of
the
inpu
t rec
eive
d fro
m th
ese
grou
ps.
Whi
le th
e C
FPB
is in
the
proc
ess
of d
evel
opin
g th
e se
arch
able
con
tent
reso
urce
, as
soon
as
Con
sum
er
Affa
irs re
ceiv
es b
oth
inte
rnal
and
ext
erna
l rep
orts
, the
y sh
are
exce
rpts
and
key
poi
nts
with
oth
er C
FPB
staf
f.
Low
• Th
e co
mpl
ete
deve
lopm
ent o
f a s
earc
habl
e co
nten
t re
sour
ce w
ill be
a te
rrific
way
to s
hare
info
rmat
ion
and
max
imize
bur
eau
reso
urce
s.
Be a
reso
urce
to c
onsu
mer
, civ
il rig
hts
and
nonp
rofit
orga
niza
tions
, and
hel
p al
l pa
rts o
f the
CFP
B ac
cess
kn
owle
dge
and
info
rmat
ion
from
thos
e gr
oups
.
Roun
dtab
les
held
by
the
CFPB
brin
g to
geth
er k
ey
cons
tituen
cy g
roup
s, in
cludi
ng o
lder
Am
erica
ns, s
tude
nts,
and
m
inor
ity g
roup
s an
d cr
eate
a tw
o-wa
y di
alog
ue. A
n in
tern
al
week
ly lo
ok-a
-hea
d do
cum
ent is
pro
vided
to a
ll CFP
B pe
rson
nel s
o th
ey c
an s
ee u
pcom
ing
exte
rnal
mee
tings
takin
g pl
ace
in th
e ev
ent it
mak
es s
ense
for o
ther
gro
ups
with
in
CFPB
to p
artic
ipat
e as
wel
l. Add
itiona
l res
ourc
es in
clude
: so
cial m
edia
, the
web
site
and
the
800
num
ber.
Med
ium
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Adhe
re to
Sec
tion
1013
(a)(5
) of
the
Dodd
-Fra
nk A
ct
CFPB
has
eva
luat
ed th
e O
mbu
dsm
an fu
nctio
n wi
thin
oth
er
fede
ral a
genc
ies
and
cond
ucte
d so
me
inte
rnal
pla
nnin
g.
Addi
tiona
lly, a
det
aile
e ha
s be
en a
ssig
ned
to th
e O
ffice
of th
e O
mbu
dsm
an.
Howe
ver,
the
Om
buds
man
func
tion
is no
t yet
up
and
runn
ing
as a
com
plet
e fu
nctio
ning
offic
e.
High
• Th
e po
sitio
n of
Om
buds
man
is m
anda
ted
by th
e Do
dd-
Fran
k Ac
t in E
xter
nal A
ffairs
and
its ro
le w
ithin
the
orga
niza
tion
is an
impo
rtant
one
. Fur
ther
, a d
etai
lee
in th
is po
sitio
n co
uld
face
som
e ch
alle
nges
in fu
lfillin
g a
role
that
re
quire
s in
tern
al in
vest
igat
ion
give
n th
at e
mpl
oyee
s co
uld
view
him
/her
as
tem
pora
ry a
nd b
e le
ss th
an fu
lly
coop
erat
ive.
• Th
us w
e re
com
men
d th
at th
e CF
PB fil
l the
posit
ion
with
a
full-t
ime
empl
oyee
as
soon
as
poss
ible
.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
92
Goa
l Sc
ore
Sum
mar
y of
Per
form
ance
Pr
iorit
y F
indi
ng /
Reco
mm
enda
tion
Adhe
re to
Sec
tion
1014
of t
he
Dodd
-Fra
nk A
ct
W
ithou
t a D
irect
or, C
FPB
is st
atut
orily
una
ble
to h
ave
a fu
nctio
ning
Con
sum
er A
dviso
ry B
oard
. Hi
gh
• W
hile
the
Cons
umer
Adv
isory
Boa
rd h
as a
n im
porta
nt
func
tion
with
in th
e or
gani
zatio
n an
d is
man
date
d by
the
Dodd
-Fra
nk A
ct in
ext
erna
l affa
irs, b
y la
w, th
e Bo
ard
cann
ot
be c
reat
ed u
ntil t
he D
irect
or o
f the
CFP
B is
in p
lace
.
• Th
us w
e re
com
men
d th
e Bo
ard
be c
reat
ed a
s so
on a
s po
ssib
le fo
llowi
ng th
e ap
prov
al o
f a D
irect
or.
Adhe
re to
Title
10,
Sec
tion
1013
(e) o
f the
Dod
d-Fr
ank
Act
CFPB
has
cre
ated
the
Offic
e of
Ser
vicem
embe
r Affa
irs.
High
•
In o
ur ju
dgm
ent,
base
d on
the
info
rmat
ion
prov
ided
, the
CF
PB h
as m
et its
obl
igat
ions
in th
is ar
ea.
Adhe
re to
Title
10,
Sec
tion
1013
(g) o
f the
Dod
d-Fr
ank
Act
As o
utlin
ed in
Dod
d-Fr
ank,
CFP
B is
not r
equi
red
to h
ave
crea
ted
the
Offic
e of
Fin
ancia
l Pro
tect
ion
for O
lder
Am
erica
ns
until
Janu
ary
21, 2
012.
Alth
ough
the
Offic
e of
Fin
ancia
l Pr
otec
tion
for O
lder
Am
erica
ns is
not
eva
luat
ed in
this
repo
rt,
since
the
Offic
e wa
s cr
eate
d on
Aug
ust 2
8, th
e ac
ting
dire
ctor
of
the
Offic
e m
et w
ith n
umer
ous
gove
rnm
enta
l offic
es a
nd
stak
ehol
ders
invo
lved
in is
sues
affe
ctin
g O
lder
Am
erica
ns,
cons
isten
t with
CFP
B’s
stat
utor
y m
anda
te. T
he p
erm
anen
t As
sista
nt D
irect
or w
ill be
on
boar
d on
Oct
ober
17.
Med
ium
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Adhe
re to
Title
10,
Sec
tion
1035
of t
he D
odd-
Fran
k Ac
t
As o
utlin
ed in
the
Dodd
-Fra
nk A
ct, C
FPB
is no
t req
uire
d to
ha
ve d
esig
nate
d a
Priva
te E
duca
tion
Loan
Om
buds
man
unt
il O
ctob
er 2
1, 2
011.
Give
n th
at, t
he fu
nctio
n of
Priv
ate
Educ
atio
n Lo
an O
mbu
dsm
an is
not
eva
luat
ed in
the
rem
aind
er
of th
is re
port.
High
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Adhe
re to
Title
10,
Sec
tion
1013
(d) o
f the
Dod
d-Fr
ank
Act
CFPB
has
cre
ated
the
Offic
e of
Fin
ancia
l Edu
catio
n. H
owev
er,
give
n th
e ne
wnes
s of
the
offic
e at
this
time,
it is
not e
valu
ated
in
the
rem
aind
er o
f thi
s re
port.
Hi
gh
• W
e re
com
men
d th
at th
e CF
PB c
ontin
ue w
orkin
g to
ward
this
bein
g a
fully
func
tiona
l offic
e.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
93
Goa
l Sc
ore
Sum
mar
y of
Per
form
ance
Pr
iorit
y F
indi
ng /
Reco
mm
enda
tion
Adhe
re to
the
Free
dom
of
Info
rmat
ion
Act (
FOIA
)
CFPB
has
dem
onst
rate
d ex
empl
ary
com
plia
nce
with
FO
IA.
The
FOIA
Offic
e ha
s ad
opte
d a
“disc
retio
nary
” app
roac
h un
der
which
tran
spar
ency
take
s pr
eced
ence
. At
this
stag
e in
its
yout
hful
hist
ory,
the
FOIA
Offic
e ha
s cr
eate
d an
d be
gun
impl
emen
ting
inte
rnal
pro
cess
and
pro
cedu
res
for r
espo
ndin
g to
FO
IA re
ques
ts in
a s
tream
lined
man
ner,
and
has
mad
e sig
nific
ant e
fforts
to e
nsur
e th
at a
ll app
ropr
iate
offic
es w
ithin
CF
PB a
re m
ade
awar
e of
spe
cific
FOIA
requ
ests
that
may
be
of in
tere
st to
them
. No
tabl
y, C
FPB’
s ap
proa
ch c
ould
bec
ome
the
new
benc
hmar
k fo
r FO
IA c
ompl
ianc
e.
High
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Adhe
re to
the
E-G
over
nmen
t Ac
t of 2
002
CF
PB h
as d
evel
oped
and
impl
emen
ted
an IT
stru
ctur
e th
at
adhe
res
to th
e E-
Gov
ernm
ent A
ct, in
cludi
ng F
ISM
A.
High
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Adhe
re to
the
Fede
ral
Fund
ing
and
Acco
unta
bility
Tr
ansp
aren
cy A
ct (F
FATA
)
CFPB
pos
ts a
ward
ed fe
dera
l con
tract
s to
the
CFPB
web
site.
Hi
gh
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce e
lem
ent
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
94
Goa
l Sc
ore
Sum
mar
y of
Per
form
ance
Pr
iorit
y F
indi
ng /
Reco
mm
enda
tion
Tran
spar
ency
with
the
publ
ic
CFPB
sta
keho
lder
s cle
arly
expr
esse
d th
at a
key
obj
ectiv
e fo
r th
e bu
reau
as
a wh
ole,
and
for t
heir
indi
vidua
l dep
artm
ents
, is
to b
e tra
nspa
rent
to th
e pu
blic
thro
ugh
a va
riety
of d
iffere
nt
med
ium
s. T
his
is so
met
hing
that
was
“bak
ed in
to” t
he C
FPB
at in
cept
ion
and
has
been
mai
ntai
ned
since
. Th
e bu
reau
has
de
mon
stra
ted
its c
omm
itmen
t to
trans
pare
ncy
by b
egin
ning
to
post
Eliz
abet
h W
arre
n’s
cale
ndar
onl
ine
on N
ovem
ber 2
4,
2010
, eve
n be
fore
laun
chin
g th
e CF
PB w
ebsit
e. A
dditio
nally
, th
e CF
PB h
as h
ad n
early
100
one
-on-
one
conv
ersa
tions
with
M
embe
rs o
f Con
gres
s fro
m b
oth
sides
of t
he a
isle,
it ha
s m
et
with
a n
umbe
r of o
pen
gove
rnm
ent o
rgan
izatio
ns, a
nd h
as
prov
ided
upd
ates
on
hirin
g, in
cludi
ng lis
ting
the
nam
es a
nd
expe
rienc
e of
all s
enio
r lea
ders
hip,
and
pos
ting
upda
tes
to
prov
ide
a sn
apsh
ot o
f how
the
CFPB
is s
pend
ing
fund
s. F
utur
e co
nsid
erat
ions
in th
is ar
ea in
clude
mak
ing
addi
tiona
l do
cum
ents
and
sen
ior l
eade
rshi
p ca
lend
ars
avai
labl
e on
line,
an
d an
eFO
IA s
yste
m.
The
bure
au is
also
eva
luat
ing
the
poss
ibilit
y of
pos
ting
cons
umer
com
plai
nts
onlin
e wh
en th
ey
are
rece
ived.
High
•
Iden
tify w
ays
to s
hare
with
oth
er a
genc
ies
and
mak
e pu
blic
how
the
CFPB
has
gon
e ab
out it
s FO
IA p
roce
ss. T
his
is an
ar
ea C
FPB
can
exhi
bit s
ome
thou
ght le
ader
ship
.
Educ
ate
the
publ
ic on
who
CF
PB is
and
wha
t the
y ar
e do
ing
Mul
tiple
CFP
B st
akeh
olde
rs e
xpre
ssed
that
the
key
goal
for
them
as
exte
rnal
com
mun
icato
rs is
to e
nsur
e th
at c
onsu
mer
s kn
ow w
ho C
FPB
is an
d wh
at th
e bu
reau
is d
oing
. Th
us fa
r, CF
PB h
as s
ucce
ssfu
lly u
sed
its w
ebsit
e an
d bl
og to
co
mm
unica
te w
hat is
goi
ng o
n in
side
the
bure
au a
s we
ll as
to
dem
onst
rate
its c
omm
itmen
t to
trans
pare
ncy
as d
escr
ibed
pr
evio
usly.
Add
itiona
lly, C
FPB
cons
isten
tly u
ses
back
chan
nel
com
mun
icatio
ns (i
.e.,
pers
onal
pho
ne c
alls
to c
onsu
mer
gr
oups
) to
cont
inue
to e
duca
te th
e pu
blic
on C
FPB
oper
atio
ns
(e.g
., th
roug
h th
e Co
mm
unity
Affa
irs O
ffice,
all j
ob
anno
unce
men
ts a
re s
ent t
o th
e O
ffice’
s lis
t of c
onsu
mer
gr
oups
).
Med
ium
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
95
Goa
l Sc
ore
Sum
mar
y of
Per
form
ance
Pr
iorit
y F
indi
ng /
Reco
mm
enda
tion
Mee
t with
com
mun
ity b
anke
rs
from
all 5
0 st
ates
CFPB
not
onl
y m
et b
ut e
xcee
ded
thei
r goa
l of m
eetin
g wi
th
com
mun
ity b
anke
rs fr
om a
ll 50
stat
es w
ithin
one
yea
r; in
fact
, th
ey re
ache
d th
eir g
oal w
ell b
efor
e th
e de
adlin
e.
The
CFPB
al
so c
ontin
ues
outre
ach
to c
omm
unity
ban
kers
(e.g
., du
ring
the
week
s of
Sep
tem
ber 1
2th a
nd 1
9th, C
FPB
spok
e wi
th
com
mun
ity b
anke
rs fr
om 1
7 di
ffere
nt s
tate
s).
Med
ium
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
CFPB
-wid
e sh
ared
visi
on o
f th
e ro
le o
f eng
agem
ent a
nd
the
desir
ed im
pact
on
the
publ
ic of
our
eng
agem
ent
work
Cons
umer
Eng
agem
ent h
as h
eld
two
work
ing
sess
ions
to
defin
e th
e of
fice’
s m
issio
n an
d vis
ion,
and
a d
raft
miss
ion
stat
emen
t has
bee
n de
velo
ped.
The
Offic
e ha
s al
so w
orke
d in
co
llabo
ratio
n wi
th o
ther
CFP
B of
fices
to d
evel
op lo
ng-te
rm
visio
ns fo
r cur
rent
CFP
B di
gita
l eng
agem
ent o
fferin
gs.
High
• Co
nsum
er E
ngag
emen
t sho
uld
cont
inue
to w
ork
on d
efin
ing
its o
wn m
issio
n an
d vis
ion,
ens
urin
g th
at th
ey a
re in
ag
reem
ent w
ith th
e m
issio
n an
d vis
ion
of th
e CF
PB a
s a
whol
e. D
evel
opin
g a
coor
dina
ted
miss
ion
and
visio
n wi
ll st
reng
then
the
CFPB
bra
nd o
ver t
ime.
Org
aniza
tiona
l stru
ctur
e,
posit
ion
desc
riptio
ns, c
aree
r la
dder
s, re
crui
tmen
t pla
n, a
nd
polic
ies
to s
uppo
rt th
e wo
rk
(exa
mpl
e, “b
log
on o
ther
sit
es” p
olicy
)
Whi
le C
onsu
mer
Eng
agem
ent h
as d
efer
red
recr
uitin
g ef
forts
to
2Q 2
012,
it ha
s fo
cuse
d its
atte
ntio
n to
cur
rent
ly gr
owin
g th
e of
fice
from
two
to fo
ur p
erso
nnel
. Po
sitio
n de
scrip
tions
and
ca
reer
ladd
ers
for t
hose
des
crip
tions
are
eith
er in
dev
elop
men
t or
hav
e be
en d
evel
oped
. Ad
ditio
nally
, Con
sum
er
Enga
gem
ent h
as re
cogn
ized
and
iden
tified
pol
icies
for
deve
lopm
ent,
disc
ussio
n an
d im
plem
enta
tion
that
are
in th
e de
velo
pmen
t pro
cess
cur
rent
ly.
High
•
Cons
umer
Eng
agem
ent s
houl
d m
ove
quick
ly to
fill th
e of
fice
and
deve
lop
the
appr
opria
te p
lans
and
pol
icies
to a
llow
it to
effe
ctive
ly op
erat
e.
Blue
prin
t for
the
CFPB
“c
onsu
mer
exp
erie
nce,
” co
ncep
ts fo
r CFP
B pr
oduc
t an
d se
rvice
offe
rings
suc
h as
in
tera
ctive
tool
s, p
lus
plan
wi
th tim
elin
e to
brin
g on
e or
m
ore
of th
ose
mor
e sig
nific
ant
tool
s to
frui
tion
A bl
uepr
int f
or th
e CF
PB c
onsu
mer
exp
erie
nce
is on
trac
k an
d on
bud
get f
or d
elive
ry in
Dec
embe
r 201
1. T
he w
ork
is be
ing
done
thro
ugh
an o
utsid
e co
ntra
ctor
, who
will
pres
ent a
dra
ft bl
uepr
int t
o CF
PB le
ader
ship
the
week
of O
ctob
er 1
0th.
Med
ium
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
IT s
olut
ion
for e
dito
rial
work
flow
and
cont
ent
man
agem
ent s
yste
m fo
r Co
nsum
erFi
nanc
e.go
v
Cons
umer
Eng
agem
ent h
as re
ques
ted
the
appr
opria
te b
udge
t an
d pe
rson
nel r
esou
rces
for t
his
proj
ect,
and
disc
ussio
ns o
n th
e pr
ojec
t’s s
cope
, tim
elin
e an
d re
quire
men
ts h
ave
begu
n.
Med
ium
•
We
reco
mm
end
Cons
umer
Eng
agem
ent c
ontin
ue to
wor
k wi
th th
e te
chno
logy
and
info
rmat
ion
offic
es w
ithin
CFP
B to
de
velo
p th
e sc
ore,
requ
irem
ents
and
timel
ine
of th
e pr
ojec
t.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
96
Goa
l Sc
ore
Sum
mar
y of
Per
form
ance
Pr
iorit
y F
indi
ng /
Reco
mm
enda
tion
Impr
oved
bus
ines
s pr
oces
s fo
r gen
erat
ing
and
clear
ing
cont
ent f
or u
se o
n ou
r web
site
and
othe
r ele
ctro
nic
chan
nels
Beca
use
the
CFPB
ove
rall o
rgan
izatio
nal s
trate
gy p
roce
ss h
as
deem
ed th
e cle
aran
ce p
roce
ss a
s a
poss
ible
are
a fo
r im
prov
emen
t, Co
nsum
er E
ngag
emen
t has
def
erre
d wo
rk o
n th
is de
liver
able
. O
nce
it is
dete
rmin
ed w
heth
er o
r not
the
proc
ess
will b
e dr
astic
ally
chan
ged,
Con
sum
er E
ngag
emen
t wi
ll eith
er m
ove
forw
ard
with
its d
elive
rabl
e, o
r will
be h
eavil
y in
volve
d in
the
draf
ting
proc
ess.
Low
• If
it is
dete
rmin
ed th
at th
e Cl
eara
nce
Proc
ess
is in
nee
d of
im
prov
emen
t, we
reco
mm
end
cons
ider
atio
ns fo
r a m
ore
stre
amlin
ed a
ppro
ach
to th
e pr
oces
s an
d st
rong
ly en
cour
age
Cons
umer
Eng
agem
ent t
o be
invo
lved
in th
e pr
oces
s of
dev
elop
ing
a ne
w po
licy.
8-10
blo
g po
sts
each
mon
th
gene
rate
d by
the
Enga
gem
ent O
ffice,
plu
s su
ppor
t for
finan
cial e
duca
tion
cont
ent in
pos
t and
tip fo
rm
gene
rate
d by
the
OFE
(in
addi
tion
to p
osts
from
aro
und
the
bure
au)
Cons
umer
Eng
agem
ent h
as c
onsis
tent
ly wo
rked
with
oth
er
offic
es th
roug
hout
CFP
B to
dev
elop
blo
g co
nten
t tha
t sup
ports
br
oade
r out
reac
h ef
forts
to s
take
hold
er g
roup
s (i.
e., c
onsu
mer
ad
voca
cy g
roup
s, s
tude
nts,
ser
vicem
embe
rs, e
tc.).
The
Offic
e is
also
impl
emen
ting
a pi
lot p
rogr
am to
dev
elop
2 to
3 b
log
post
s pe
r wee
k ar
ound
a “C
FPB
in y
our c
omm
unity
” the
me
that
hig
hlig
hts
CFPB
sen
ior l
eade
rshi
p vis
iting
exte
rnal
st
akeh
olde
rs.
Med
ium
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Cons
isten
t pro
mot
ion
of o
ur
mon
ey e
duca
tion
cont
ent
such
as
tip o
f the
day
to o
ther
sit
es/c
hann
els
Whi
le C
onsu
mer
Eng
agem
ent is
wor
king
in c
olla
bora
tion
with
th
e O
ffice
of F
inan
cial E
duca
tion
to p
lan
for p
ostin
g, p
rom
otin
g an
d di
strib
utin
g th
is co
nten
t as
soon
as
it is
avai
labl
e fo
r pu
blica
tion,
som
e of
this
work
will
be d
epen
dent
on
the
deve
lopm
ent o
f the
blu
eprin
t men
tione
d ab
ove.
Med
ium
•
We
reco
mm
end
Cons
umer
Eng
agem
ent c
ontin
ue to
pla
n fo
r th
e pr
omot
ion
of e
duca
tion
cont
ent t
o en
sure
pro
mot
ion
is as
se
amle
ss a
s po
ssib
le o
nce
it is
read
y fo
r pub
licat
ion.
Web
por
tals
for t
he
empo
werm
ent o
ffices
plu
s O
FE (M
y Fi
) and
Fai
r Len
ding
The
Offic
e of
Fai
r Len
ding
and
Equ
al O
ppor
tuni
ty’s
web
porta
l an
d an
impr
oved
site
for t
he O
ffice
of C
omm
unity
Ban
ks a
nd
Cred
it Uni
ons
will l
aunc
h on
Oct
ober
2nd
. An
upd
ated
OSA
we
b po
rtal w
ill be
laun
ched
late
r in
Oct
ober
.
Med
ium
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
One
to tw
o in
itial o
fferin
gs to
en
gage
the
publ
ic on
mon
ey
issue
s or
mon
ey d
ecisi
on-
mak
ing
in c
lose
coo
pera
tion
with
OFE
Th
is de
liver
able
is d
epen
dent
on
the
cons
umer
exp
erie
nce
blue
prin
t out
lined
abo
ve.
High
•
We
reco
mm
end
CFPB
con
tinue
to m
ove
forw
ard
with
the
cons
umer
exp
erie
nce
blue
prin
t so
that
wor
k th
at is
de
pend
ent o
n it c
an m
ove
forw
ard.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
97
Goa
l Sc
ore
Sum
mar
y of
Per
form
ance
Pr
iorit
y F
indi
ng /
Reco
mm
enda
tion
Desig
n an
d im
plem
enta
tion
of
cale
ndar
for u
se o
f dire
ct
emai
l tool
Beca
use
of th
e CF
PB-w
ide
stra
tegy
pro
cess
und
erwa
y, a
n in
terim
stra
tegy
pla
n wa
s pu
t in p
lace
for a
n ed
itoria
l cal
enda
r an
d th
e bu
ildin
g of
targ
eted
list s
egm
ents
. Co
nsum
er
Enga
gem
ent le
d th
e ef
fort
to d
evel
op th
e in
terim
stra
tegy
, and
wi
ll lea
d th
e lo
ng-te
rm p
roce
ss m
ovin
g fo
rwar
d.
Med
ium
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Web
stre
amin
g ca
pacit
y (fo
r O
ct O
SA c
onve
ning
, en
forc
emen
t hea
rings
)
Cons
umer
Eng
agem
ent,
in c
olla
bora
tion
with
the
info
rmat
ion
and
tech
nolo
gy o
ffices
, suc
cess
fully
stre
amed
Raj
Dat
e’s
9/15
Ph
ilade
lphi
a sp
eech
live
on th
e CF
PB w
ebsit
e. P
lans
to liv
e st
ream
two
mor
e ev
ents
this
mon
th a
re in
pla
ce.
Med
ium
•
We
enco
urag
e CF
PB to
con
tinue
to u
se liv
e st
ream
ing
as a
co
mm
unica
tions
tool
, as
it allo
ws th
ose
who
are
unab
le to
at
tend
CFP
B ev
ents
the
oppo
rtuni
ty to
be
a pa
rt of
them
.
Deve
lop
milit
ary
cont
ent f
or
webs
ite/s
ocia
l med
ia
OSA
has
dev
elop
ed n
umer
ous
sour
ces
of w
eb c
onte
nt,
inclu
ding
a s
pecif
ic la
ndin
g pa
ge o
n th
e CF
PB w
ebsit
e fo
r se
rvice
mem
bers
that
hig
hlig
hts
who
OSA
is a
nd w
hat t
hey
are
doin
g fo
r mem
bers
of t
he m
ilitar
y an
d th
eir f
amilie
s, a
nd
num
erou
s bl
og p
osts
and
arti
cles
rega
rdin
g th
e ha
ppen
ings
in
side
OSA
and
the
even
ts, s
peec
hes,
etc
. tha
t Hol
ly Pe
traeu
s ha
s pa
rticip
ated
in.
Med
ium
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Host
con
veni
ng in
Oct
ober
co
ncer
ning
bes
t pra
ctice
s in
of
ferin
g fin
ancia
l pro
duct
s to
m
ilitar
y
OSA
has
rele
ased
a R
eque
st fo
r Inf
orm
atio
n via
the
Fede
ral
Regi
ster
to g
ain
insig
ht o
n th
e pr
oduc
ts a
nd s
ervic
es th
at a
re
mos
t uni
que
to s
ervic
emem
bers
and
thei
r fam
ilies.
An
orig
inal
O
ctob
er c
onve
ning
dat
e wa
s m
oved
to N
ovem
ber d
ue to
lo
gist
ical c
onflic
ts w
ith S
tude
nt a
nd O
lder
Am
erica
n ro
llout
ev
ents
. Pl
anni
ng is
wel
l und
erwa
y fo
r the
Nov
embe
r eve
nt,
thou
gh th
at d
ate
may
be
mov
ed b
ack
as to
avo
id a
con
flict w
ith
Pres
iden
t Oba
ma’
s Fi
nanc
ial E
duca
tion
Sum
mit.
Pla
nnin
g th
us fa
r has
inclu
ded
iden
tifyin
g pa
nel s
peak
ers,
cre
atin
g qu
estio
n se
ts, a
nd fig
urin
g ou
t logi
stica
l info
rmat
ion.
Med
ium
•
We
reco
mm
end
the
CFPB
con
tinue
the
plan
ning
pro
cess
al
read
y un
derw
ay fo
r the
con
veni
ng e
vent
.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
98
Goa
l Sc
ore
Sum
mar
y of
Per
form
ance
Pr
iorit
y F
indi
ng /
Reco
mm
enda
tion
Eval
uate
finan
cial e
duca
tion
at m
ilitar
y ba
sic tr
aini
ng
Mem
bers
of O
SA h
ave
visite
d ba
sic tr
aini
ng s
ites
of tw
o m
ilitar
y di
visio
ns: t
he N
avy
and
Mar
ine
Corp
s. O
SA is
sch
edul
ed to
vis
it the
bas
ic tra
inin
g sit
e fo
r the
Arm
y at
For
t Jac
kson
on
Nove
mbe
r 4, 2
011.
Visi
ts to
the
Air F
orce
and
Coa
st G
uard
ba
sic tr
aini
ng s
ites
are
curre
ntly
bein
g sc
hedu
led.
So
far,
OSA
ha
s m
ade
only
initia
l obs
erva
tions
, but
wan
t to
focu
s on
the
begi
nnin
g of
milit
ary
care
ers
and
the
use
of te
chno
logy
to
mod
erni
ze fin
ancia
l edu
catio
n fo
r new
mem
bers
of t
he m
ilitar
y.
Med
ium
• W
e re
com
men
d th
e CF
PB c
ontin
ue to
mov
e fo
rwar
d wi
th
plan
ning
visi
ts to
the
rem
aini
ng m
ilitar
y ba
sic tr
aini
ng s
ites
in
orde
r to
reac
h its
goa
l of g
oing
to a
ll milit
ary
divis
ion
basic
tra
inin
g sit
es b
y Ja
nuar
y 20
12.
Deve
lop
revis
ed c
urric
ulum
fo
r new
recr
uits
in
coor
dina
tion
with
Dep
t. of
De
fens
e
The
deve
lopm
ent o
f rev
ised
curri
culu
m fo
r new
recr
uits
is
unde
rway
with
DoD
; OSA
is in
a d
ata-
gath
erin
g ph
ase.
In
itial o
bser
vatio
ns s
how
a va
rianc
e am
ong
curri
culu
ms
acro
ss
milit
ary
divis
ions
.
Med
ium
•
We
reco
mm
end
the
CFPB
con
tinue
its w
ork
with
DoD
mov
e fo
rwar
d wi
th b
egin
ning
to re
vise
new
recr
uit c
urric
ulum
.
Prov
ide
milit
ary
expe
rtise
for
Cons
umer
Res
pons
e: s
crip
ts,
FAQ
s, re
ferra
ls, ta
ilore
d as
sista
nce
All C
onsu
mer
Res
pons
e sc
ripts
, FAQ
s, re
ferra
ls, a
nd ta
ilore
d as
sista
nce
with
resp
ect t
o se
rvice
mem
bers
hav
e be
en
deve
lope
d wi
th e
xten
sive
OSA
inpu
t. M
ediu
m
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce e
lem
ent
Raise
awa
rene
ss o
f CF
PB/O
SA th
roug
h m
edia
, sp
eech
es a
nd o
utre
ach
to
busin
ess
and
gove
rnm
ent
CFPB
and
OSA
hav
e bo
th e
xten
sivel
y us
ed C
FPB’
s bl
og to
di
ssem
inat
e in
form
atio
n re
gard
ing
the
happ
enin
gs in
the
Bure
au a
s a
whol
e an
d O
SA.
Both
hav
e us
ed th
e bl
og to
in
form
the
publ
ic on
spe
eche
s an
d ev
ents
that
hav
e ta
ken
plac
e, a
s we
ll as
aske
d fo
r the
pub
lic’s
inpu
t on
mul
tiple
issu
es.
Holly
Pet
raeu
s ha
s pa
rticip
ated
in 2
6 m
eetin
gs a
nd s
peec
hes
since
her
app
oint
men
t as
Dire
ctor
of O
SA in
Jan
uary
201
1.
Exam
ples
of g
roup
s sh
e ha
s sp
oken
to in
clude
wou
nded
so
ldie
rs a
t Wal
ter R
eed
Natio
nal M
ilitar
y M
edica
l Cen
ter,
the
Asso
ciatio
n of
Milit
ary
Bank
s, th
e Ar
my
JAG
Sch
ool, t
he
Wou
nded
War
riors
pro
ject
, and
mem
bers
of t
he U
.S. H
ouse
an
d Se
nate
. M
embe
rs o
f the
OSA
team
hav
e he
ld n
umer
ous
town
halls
and
roun
dtab
les
and
trave
led
to m
ilitar
y ba
ses
acro
ss th
e co
untry
to c
reat
e a
feed
back
loop
thro
ugh
which
O
SA c
an e
duca
te m
embe
rs o
f the
milit
ary
on w
hat is
goi
ng o
n in
side
the
offic
e an
d O
SA c
an le
arn
from
milit
ary
mem
bers
wh
at is
sues
are
the
mos
t impo
rtant
to th
em.
Med
ium
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
99
Tab
le 2
3: A
lign
men
t w
ith
Per
form
ance
Sta
nd
ard
s (A
ud
ien
ces)
Audi
ence
Sc
ore
Sum
mar
y of
Per
form
ance
Pr
iorit
y F
indi
ng /
Reco
mm
enda
tion
Cons
umer
s
As a
con
sum
er-fo
cuse
d or
gani
zatio
n, th
e CF
PB h
as u
nder
stan
dabl
y m
ade
cons
umer
s th
eir p
riorit
y au
dien
ce. C
FPB’
s we
bsite
is u
ser-
frien
dly
both
in n
avig
atio
n an
d in
con
tent
acc
essib
ility
and
unde
rsta
ndin
g. M
oreo
ver,
the
CFPB
has
a g
ood
stra
tegy
in b
uild
ing
rela
tions
hips
with
gro
ups
that
ser
ve a
s a
cond
uit t
o re
achi
ng
cons
umer
s. F
inal
ly, it
is de
velo
ping
a p
aral
lel ta
rget
ed a
ppro
ach
to
reac
h co
nsum
ers
with
uni
que
need
s or
circ
umst
ance
s (e
.g.,
serv
icem
embe
rs, e
thni
c gr
oups
). Th
e we
bsite
and
med
ia a
s co
mm
unica
tions
veh
icles
hav
e lim
itatio
ns, p
artic
ular
ly fo
r rur
al a
nd
low-
inco
me
popu
latio
ns.
CFPB
has
atte
mpt
ed to
alle
viate
this
by
cond
uctin
g to
wnha
lls in
low-
inco
me
area
s, in
cludi
ng e
vent
s in
Ohi
o,
Mon
tana
and
San
Fra
ncisc
o. G
iven
the
spec
ial c
halle
nges
with
en
gagi
ng th
ese
grou
ps, c
oord
inat
ion
betw
een
depa
rtmen
ts w
ithin
Ex
tern
al A
ffairs
to le
vera
ge re
latio
nshi
ps w
ith th
ird-p
arty
gro
ups
is an
d wi
ll con
tinue
to b
e im
porta
nt g
oing
forw
ard.
Th
e bu
reau
has
also
em
brac
ed th
e im
porta
nce
of p
rovid
ing
mul
ti-lin
gual
ser
vices
, co-
deve
lopi
ng (n
ot tr
ansla
ting)
the
reva
mpe
d m
ortg
age
disc
losu
re
docu
men
ts fr
om K
now
Befo
re Y
ou O
we fo
r Spa
nish
use
. A
fully
fu
nctio
nal S
pani
sh w
ebsit
e is
also
in d
evel
opm
ent.
The
CFPB
’s 80
0 nu
mbe
r is
avai
labl
e in
189
lang
uage
s, a
nd th
ey w
ere
the
first
fede
ral
bure
au to
twee
t in S
pani
sh. O
f the
419
in-p
erso
n m
eetin
gs E
lizab
eth
War
ren
cond
ucte
d wi
th v
ario
us g
roup
s, m
ore
19%
wer
e wi
th
cons
umer
gro
ups.
High
• Ad
ding
add
itiona
l lang
uage
s to
the
webs
ite a
nd g
ener
atin
g se
lect
m
ater
ials
in o
ther
lang
uage
s wi
ll allo
w th
e CF
PB to
eng
age
cons
umer
s in
pop
ulat
ions
it ca
n on
ly re
ach
indi
rect
ly at
this
poin
t in
time.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
100
Audi
ence
Sc
ore
Sum
mar
y of
Per
form
ance
Pr
iorit
y F
indi
ng /
Reco
mm
enda
tion
Polic
ymak
ers
CFPB
’s O
ffice
of L
egisl
ative
Affa
irs h
as c
omm
unica
ted
regu
larly
sin
ce it
bega
n its
wor
k wi
th fe
dera
l pol
icym
aker
s by
dev
elop
ing
repo
rts o
n th
e CF
PB’s
prog
ress
, pro
vidin
g te
stim
ony
and
regu
lar p
hone
cal
ls to
kee
p M
embe
rs o
f Con
gres
s in
form
ed o
n iss
ues
and
initia
tives
. Ph
one
calls
pr
ior t
o a
maj
or a
nnou
ncem
ent f
rom
the
CFPB
to S
enat
e Ba
nkin
g an
d Ho
use
Fina
ncia
l Ser
vices
com
mitte
es e
nsur
e no
sur
prise
s fo
r la
wmak
ers.
Eliz
abet
h W
arre
n te
stifie
d be
fore
Con
gres
s on
thre
e oc
casio
ns in
201
1 to
pro
vide
upda
tes
on C
FPB
in M
arch
, May
and
Ju
ly. C
FPB
offic
ials
have
test
ified
a to
tal o
f 11
times
bef
ore
Cong
ress
th
us fa
r in
2011
to p
rovid
e up
date
s. A
lso, in
add
ition
to
Mem
oran
dum
s of
Und
erst
andi
ng (M
OU’
s) in
pla
ce w
ith s
tate
atto
rney
ge
nera
ls, m
eetin
gs h
ave
take
n pl
ace
inclu
ding
one
mee
ting
with
sta
te
AGs
that
inclu
ded
mem
bers
of C
FPB
staf
f fro
m e
very
divi
sion.
Of t
he
419
in-p
erso
n m
eetin
gs E
lizab
eth
War
ren
cond
ucte
d wi
th v
ario
us
grou
ps, m
ore
than
a q
uarte
r (26
%) w
ere
on th
e Hi
ll.
Med
ium
• Th
e In
terg
ov o
ffice
was
rece
ntly
staf
fed,
and
will
be re
spon
sible
fo
r dev
elop
ing
rela
tions
hips
with
sta
te, lo
cal a
nd in
tern
atio
nal
offic
ials.
Ful
l func
tiona
lity o
f thi
s of
fice
will f
urth
er e
nhan
ce th
e ab
ility
for t
he C
FPB
to d
emon
stra
te its
sup
port
and
impa
ct a
nd
also
to s
olici
t info
rmat
ion
at th
e st
ate
and
loca
l leve
l.
Priva
te S
ecto
r
In th
e ea
rly s
tage
s of
the
CFPB
, Eliz
abet
h W
arre
n m
ade
pers
onal
cal
ls to
lead
ers
of th
e na
tion’
s la
rges
t ban
ks, a
nd m
et w
ith le
ader
s of
thos
e ba
nks
when
ever
sch
edul
es a
llowe
d tra
vel to
New
Yor
k Ci
ty.
Prio
r to
the
CFPB
Pro
gres
s Re
port
rele
ase
in J
uly,
the
sam
e le
ader
s we
re
mad
e aw
are
of th
e co
min
g re
port.
The
ope
ratio
n to
eng
age
larg
e pa
rticip
ants
is s
till b
eing
def
ined
give
n th
at: (
1) s
uper
visor
y in
tera
ctio
n pr
ovid
es a
nat
ural
con
duit f
or c
omm
unica
tion;
and
(2) t
he A
dviso
ry
Boar
d wi
ll hel
p sh
ape
what
this
even
tual
ly lo
oks
like.
How
ever
, CFP
B ha
s de
velo
ped
an o
ngoi
ng d
ialo
gue
with
com
mun
ity b
anks
thro
ugh
dire
ct o
utre
ach,
and
trad
e gr
oups
suc
h as
ICBA
and
ABA
. Of t
he 4
19
in-p
erso
n m
eetin
gs E
lizab
eth
War
ren
cond
ucte
d wi
th v
ario
us g
roup
s,
near
ly ha
lf (47
%) w
ere
with
finan
cial s
ervic
es fir
ms,
com
mun
ity b
anks
an
d cr
edit u
nion
s.
Med
ium
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
101
Audi
ence
Sc
ore
Sum
mar
y of
Per
form
ance
Pr
iorit
y F
indi
ng /
Reco
mm
enda
tion
Third
Par
ty
Org
aniza
tions
CFPB
’s co
nsum
er fo
cus
has
mad
e in
tera
ctio
ns w
ith th
ird p
artie
s,
parti
cula
rly c
onsu
mer
gro
ups,
a p
riorit
y. T
hey
have
em
brac
ed th
e ne
ed to
kee
p an
ope
n lin
e of
com
mun
icatio
n wi
th k
ey th
ird p
arty
gr
oups
(e.g
., Co
nsum
ers
Unio
n an
d Am
erica
ns fo
r Fin
ancia
l Ref
orm
). W
hile
the
CFPB
’s in
tent
ions
in th
is ar
ea a
re a
dvan
ced
base
d on
co
nver
satio
ns w
ith s
taff,
mor
e do
cum
ente
d pl
anni
ng w
ould
be
usef
ul
parti
cula
rly a
s ot
her d
epar
tmen
ts lo
ok to
leve
rage
third
par
ty
tract
ion/
awar
enes
s an
d th
us m
axim
ize s
ourc
es. C
FPB
has
reco
gnize
d th
e ne
ed to
tailo
r the
ir se
rvice
s to
sel
ect E
nglis
h-se
cond
la
ngua
ge p
opul
atio
ns w
ho h
ave
been
par
ticul
arly
affe
cted
by
the
finan
cial c
risis.
The
CFP
B’s
800
num
ber i
s av
aila
ble
in 1
89
lang
uage
s, a
nd th
ey w
ere
the
first
fede
ral b
urea
u to
twee
t in S
pani
sh.
High
• W
e re
com
men
d m
ore
docu
men
ted
plan
ning
so
that
the
CFP
B ca
n ou
tline
key
targ
et g
roup
s, a
sses
s th
ose
rela
tions
hips
and
ot
her d
epar
tmen
ts w
ithin
the
CFPB
can
leve
rage
third
par
ty
tract
ion/
awar
enes
s as
wel
l.
Med
ia
Med
ia is
an
impo
rtant
aud
ienc
e fo
r the
CFP
B gi
ven
that
it is
ofte
n th
e wa
y co
nsum
ers
lear
n ab
out t
he b
urea
u. T
he C
FPB
has
crea
ted
the
Med
ia R
elat
ions
offic
e an
d pl
aced
a p
rem
ium
of b
eing
act
ive in
this
area
, whi
ch re
sults
sug
gest
has
pai
d of
f. F
eedb
ack
from
repo
rters
we
spok
e wi
th in
dica
te th
at C
FPB
staf
f are
resp
onsiv
e an
d in
form
ed.
Med
ium
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
102
Tab
le 2
4: A
lign
men
t w
ith
Per
form
ance
Sta
nd
ard
s (P
olic
ies
and
Pro
cess
es)
Polic
y / P
roce
ss
Scor
e Su
mm
ary
of P
erfo
rman
ce
Prio
rity
Reco
mm
enda
tions
Clea
ranc
e Pr
oces
s
CFPB
dev
elop
ed a
nd d
istrib
utes
to a
ll new
em
ploy
ees
a po
licy
docu
men
t tha
t out
lines
am
ong
othe
r thi
ngs
the
clear
ance
pro
cess
. It in
clude
s th
e pr
oces
s al
l sta
ff sh
ould
us
e fo
r int
erna
l and
ext
erna
l doc
umen
ts in
cludi
ng
mai
ntai
ning
reco
rds
of th
e do
cum
ents
as
well a
s de
tail
abou
t doc
umen
t typ
e an
d ap
prop
riate
timel
ines
for i
nter
nal
revie
w an
d ap
prov
al.
Low
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce e
lem
ent
Mor
ning
Mee
ting
– Ex
tern
al
Com
mun
icato
rs
A m
orni
ng m
eetin
g wi
th a
ll ext
erna
l com
mun
icato
rs e
nsur
es
that
the
CFPB
is s
peak
ing
with
one
voi
ce, a
nd th
at a
ll m
embe
rs o
f the
team
are
on
the
sam
e pa
ge.
Low
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce e
lem
ent
FOIA
Pro
cess
FOIA
is a
requ
ired
com
pone
nt fo
r cre
atin
g tra
nspa
renc
y wi
th th
e pu
blic.
CFP
B ha
s es
tabl
ished
and
impl
emen
ted
a FO
IA p
roce
ss th
at is
exp
lain
ed c
lear
ly an
d th
orou
ghly
on
the
webs
ite fo
r int
eres
ted
parti
es. I
nter
nally
, the
pro
cess
has
be
en c
lear
ly de
fined
usin
g a
proc
ess
map
that
out
lines
im
porta
nt p
oint
s of
dec
ision
-mak
ing
with
in th
e CF
PB, a
pr
oces
sing
mod
el c
heck
list,
and
timel
ine
that
inclu
des
actio
n ite
ms,
goa
ls an
d co
mpl
etio
n da
te. T
he C
FPB
has
plac
ed a
n em
phas
is he
re a
nd it’
s ap
pare
nt. W
ith th
e im
plem
enta
tion
of th
e eF
OIA
sys
tem
, item
s su
ch a
s a
read
ing
room
, FO
IA p
olicy
and
con
sum
er g
uide
may
be
adde
d.
High
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Wee
kly F
OIA
Upd
ate
with
Inte
rnal
St
akeh
olde
rs
(Awa
rene
ss M
eetin
g)
Wee
kly u
pdat
es o
n th
e FO
IA p
roce
ss p
rovid
e in
tern
al
cont
rol a
nd e
nsur
e th
at th
e ap
prop
riate
peo
ple
are
mad
e aw
are
of la
rge
or p
oten
tially
sen
sitive
requ
ests
that
hav
e be
en m
ade.
It a
lso h
ighl
ight
s iss
ues
that
may
(or m
ay n
ot)
be g
aini
ng m
omen
tum
am
ong
the
publ
ic.
Low
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce e
lem
ent
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
103
Polic
y / P
roce
ss
Scor
e Su
mm
ary
of P
erfo
rman
ce
Prio
rity
Reco
mm
enda
tions
Med
ia M
emo
A m
edia
mem
o is
dist
ribut
ed to
all e
mpl
oyee
s at
orie
ntat
ion
that
out
lines
how
to d
eal w
ith m
edia
requ
ests
and
who
is
appr
oved
to s
peak
on
beha
lf of t
he C
FPB.
Thi
s se
rves
to
avoi
d in
stan
ces
wher
e st
atem
ents
to th
e m
edia
are
mad
e by
som
eone
not
aut
horiz
ed to
do
so, a
nd o
utlin
es th
e in
tern
al s
yste
m in
pla
ce to
app
ropr
iate
ly ha
ndle
an
impo
rtant
aud
ienc
e an
d ve
hicle
for t
he C
FPB.
Low
• No
reco
mm
enda
tions
pro
vided
for t
his
perfo
rman
ce e
lem
ent
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
104
Tab
le 2
5: A
lign
men
t w
ith
Per
form
ance
Sta
nd
ard
s (M
essa
ges)
Stra
tegy
/Mes
sage
Sc
ore
Sum
mar
y of
Per
form
ance
Pr
iorit
y Re
com
men
datio
ns
The
CFPB
Mes
sage
The
CFPB
dev
elop
ed a
doc
umen
t in D
ecem
ber 2
010
calle
d Th
e CF
PB M
essa
ge th
at a
rticu
late
s th
e CF
PB’s
valu
e pr
opos
ition
for c
onsu
mer
s. H
owev
er, n
o ad
ditio
nal
mat
eria
l has
bee
n de
velo
ped
with
resp
ect t
o co
mm
unica
tions
mes
sage
s.
High
• W
hile
thou
ghtfu
l con
sider
atio
n of
the
CFPB
’s va
lue
prop
ositio
n fo
r co
nsum
ers
is wo
rthwh
ile, t
he C
FPB
shou
ld d
evel
op a
mes
sage
ar
chite
ctur
e th
at c
onsid
ers
the
spec
ific n
eeds
of a
ll of it
s au
dien
ces
(con
sum
ers,
indu
stry
, pol
icym
aker
s, e
tc.).
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
105
Tab
le 2
6: A
lign
men
t w
ith
Per
form
ance
Sta
nd
ard
s (V
ehic
les
and
Mat
eria
ls)
Vehi
cle
/ Mat
eria
l Sc
ore
Sum
mar
y of
Per
form
ance
Pr
iorit
y Re
com
men
datio
ns
CFPB
Web
site
The
CFPB
’s we
bsite
is a
n im
porta
nt fo
rm o
f com
mun
icatio
n wi
th th
e pu
blic
for t
he C
FPB.
The
web
site
is ea
sy to
na
vigat
e an
d de
liber
atel
y ea
sy to
read
(dev
elop
ed ta
rget
ing
an 8
th g
rade
read
ing
leve
l). I
t also
inclu
des
info
rmat
ion
on
what
has
bee
n go
ing
on in
the
bure
au (s
ee b
elow
), in
cludi
ng
Requ
ests
for C
omm
ent a
nd in
form
atio
n on
thei
r rec
ent
proj
ects
(e.g
., Kn
ow B
efor
e Yo
u O
we a
nd C
FPB’
s re
port
on
rem
ittanc
es).
It is
impo
rtant
to k
eep
in m
ind
that
the
web
only
reac
hes
a se
lect
por
tion
of th
e po
pula
tion
and
as s
uch,
not
fa
ll pre
y to
ass
umin
g if i
t’s o
n th
e we
b, it’
s re
achi
ng p
eopl
e.
Med
ium
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
CFPB
Blo
g
The
CFPB
blo
g, w
ithin
the
webs
ite, s
erve
s as
a v
ehicl
e fo
r co
mm
unica
ting
what
CFP
B is
doin
g as
a b
urea
u. I
t also
se
rves
as
a wa
y fo
r CFP
B to
resp
ond
to c
onsu
mer
inqu
iries
and
the
issue
s th
at th
ey b
elie
ve a
re m
ost im
porta
nt (e
.g.,
a Tw
itter p
ost h
ighl
ight
ed in
a J
uly
15, 2
011
by Th
e New
York
Tim
es o
n m
ortg
age
disc
losu
re fo
rms
that
the
bure
au
resp
onde
d to
via
a v
ideo
pos
t on
its b
log)
.
Low
• As
the
orga
niza
tion
mat
ures
and
the
staf
f gro
ws, C
FPB
shou
ld s
trive
to
incr
ease
the
frequ
ency
of b
log
post
s (c
urre
ntly
abou
t one
per
wee
k), in
or
der t
o m
ake
this
a m
ore
robu
st c
omm
unica
tions
tool
.
Even
ts/S
peec
hes
CFPB
eve
nts/
spee
ches
give
a fa
ce to
the
bure
au, s
howi
ng
cons
umer
s th
e le
ader
s of
the
orga
niza
tion
and
prov
idin
g a
chan
ce to
furth
er c
omm
unica
te th
e m
essa
ge a
nd p
rogr
ess
of th
e CF
PB. L
ocal
town
hal
l eve
nts
and
spee
ches
are
a
regu
lar f
orm
of c
omm
unica
tion
at C
FPB.
Live
stre
amin
g an
d po
stin
g vid
eos
of s
peec
hes/
even
ts o
n th
e we
bsite
pro
vide
an a
dditio
nal w
ay fo
r peo
ple
who
coul
d no
t atte
nd th
e ev
ent
to b
e in
clude
d (e
.g.,
lives
tream
ing
of R
aj D
ate’
s sp
eech
in
Phila
delp
hia
on S
epte
mbe
r 15,
201
1).
Med
ium
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
106
Vehi
cle
/ Mat
eria
l Sc
ore
Sum
mar
y of
Per
form
ance
Pr
iorit
y Re
com
men
datio
ns
Pres
s
The
pres
s is
both
an
audi
ence
unt
o its
elf a
s we
ll as
a ve
hicle
to
reac
h ot
her a
udie
nces
. Bas
ed o
n a
med
ia s
can
of to
p-tie
r m
edia
, the
CFP
B ha
s be
en e
ffect
ive in
usin
g th
e pr
ess
as a
ve
hicle
to g
et its
mes
sage
out
. O
f par
ticul
ar n
ote
are
a nu
mbe
r of p
iece
s wr
itten
spec
ifical
ly on
CFP
B th
at p
rovid
e up
date
s on
the
CFPB
’s op
erat
ions
, pra
ise in
itiativ
es o
f the
bu
reau
(i.e
., Kn
ow B
efor
e Yo
u O
we),
or h
ighl
ight
its
inte
ract
ion
with
the
publ
ic.
Med
ium
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Web
inar
s/Li
vest
ream
CFPB
has
follo
wed
thro
ugh
on p
lans
to u
se w
ebin
ars
to
gene
rate
a d
ialo
gue
betw
een
the
bure
au a
nd o
utsid
e gr
oups
, inclu
ding
with
com
mun
ity b
anks
, larg
e tra
de
asso
ciatio
ns, la
rge
cred
it car
d iss
uers
, cre
dit u
nion
s, a
nd
cons
umer
and
civi
l rig
hts
grou
ps.
The
CFPB
also
su
cces
sful
ly ha
d its
first
lives
tream
of a
n ev
ent o
n 9/
15/2
011
when
Raj
Dat
e’s
spee
ch in
Phi
lade
lphi
a wa
s st
ream
ed liv
e on
CFP
B’s
webs
ite.
Low
• To
dat
e th
ere
has
been
limite
d us
e of
Web
inar
s an
d Li
vest
ream
but
the
CFPB
has
hon
ored
its c
omm
itmen
t to
use
them
as
a wa
y of
co
mm
unica
tions
with
the
gene
ral p
ublic
or a
llowi
ng th
em to
par
ticip
ate
in
an e
vent
. As
the
staf
f gro
ws a
nd C
FPB
host
s/pa
rticip
ates
in m
ore
even
ts, t
his
mig
ht b
ecom
e a
mor
e ro
bust
com
mun
icatio
ns to
ol.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
107
Tab
le 2
7: A
lign
men
t w
ith
Per
form
ance
Sta
nd
ard
s (M
etri
cs o
f S
ucc
ess)
Met
ric
Scor
e Su
mm
ary
of P
erfo
rman
ce
Prio
rity
Find
ing
/ Rec
omm
enda
tion
Defin
ition
of
Com
mun
icatio
ns/M
edia
Su
cces
s
Broa
dly
the
CFPB
com
mun
icatio
ns s
taff
views
suc
cess
as
effe
ctive
ly co
mm
unica
ting
the
purp
ose
of th
e CF
PB to
co
nsum
ers.
How
ever
, diffe
rent
def
initio
ns o
f suc
cess
ex
ist a
cros
s de
partm
ents
(i.e
., on
e di
visio
n m
ay b
ase
succ
ess
on th
e nu
mbe
r of c
omm
ents
rece
ived
while
an
othe
r may
bel
ieve
suc
cess
is w
heth
er e
very
med
ia
stor
y th
at is
pitc
hed
gets
prin
ted)
. In
othe
r cas
es, t
here
are
no
def
ined
met
rics
at a
ll or t
he g
oals
that
hav
e be
en
esta
blish
ed a
re n
ot m
easu
rabl
e. M
etric
s ar
e a
chal
leng
e in
com
mun
icatio
ns a
nd u
nder
stan
dabl
y th
e CF
PB h
as
been
in a
mor
e ta
ctica
l/sur
vival
mod
e sin
ce its
cre
atio
n.
High
• As
add
itiona
l sta
ff is
adde
d, d
evot
ing
time
and
reso
urce
s to
def
ine
succ
ess
and
esta
blish
met
rics
will a
llow
the
CFPB
to e
valu
ate
itsel
f and
fo
r oth
ers
outs
ide
the
CFPB
to d
o th
e sa
me.
Also
, as
the
staf
f will
inev
itabl
y ex
perie
nce
som
e tu
rnov
er, h
avin
g do
cum
ente
d m
etric
s fo
r as
sess
ing
perfo
rman
ce is
impo
rtant
.
Wer
e ke
y st
akeh
olde
rs
enga
ged
in th
e im
plem
enta
tion
perio
d?
As d
iscus
sed
in e
arlie
r ass
essm
ents
of k
ey a
udie
nce
outre
ach,
CFP
B ha
s cle
arly
mad
e co
nsum
ers
thei
r prio
rity
audi
ence
. Th
roug
hout
the
impl
emen
tatio
n pe
riod,
co
nsum
ers
(and
third
par
ty g
roup
s) w
ere
enga
ged
thro
ugh
mul
tiple
med
ium
s, in
cludi
ng th
roug
h th
e CF
PB’s
webs
ite a
nd th
roug
h in
itiativ
es lik
e Kn
ow B
efor
e Yo
u O
we
and
the
larg
er p
artic
ipan
t Req
uest
for C
omm
ent.
Thr
ough
th
e O
ffice
of C
omm
unity
Affa
irs, c
onsu
mer
gro
ups
were
to
uche
d on
a c
onsis
tent
bas
is, w
heth
er it
was
thro
ugh
back
cha
nnel
s, o
r thr
ough
par
ticip
atio
n in
town
halls
and
ot
her C
FPB
even
ts.
Polic
ymak
ers
were
also
eng
aged
th
roug
hout
the
impl
emen
tatio
n pe
riod,
par
ticul
arly
thro
ugh
Hill b
riefin
gs a
nd te
stim
ony
by C
FPB
pers
onne
l. Hi
ll sta
ff we
re a
lso in
clude
d in
num
erou
s CF
PB e
vent
s, in
cludi
ng
pre-
brie
fing
calls
bef
ore
the
July
21st l
aunc
h, a
mor
tgag
e di
sclo
sure
sym
posiu
m, a
nd a
n ev
ent f
ocus
ed o
n th
e CA
RD A
ct.
As th
e CF
PB’s
work
with
ICBA
exh
ibits
, the
pr
ivate
sec
tor w
as a
lso e
ngag
ed th
roug
hout
the
impl
emen
tatio
n pe
riod.
Eliz
abet
h W
arre
n at
tend
ed m
any
mee
tings
and
hel
d m
any
phon
e ca
lls w
ith m
embe
rs o
f the
fin
ancia
l indu
stry
.
High
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
108
Met
ric
Scor
e Su
mm
ary
of P
erfo
rman
ce
Prio
rity
Find
ing
/ Rec
omm
enda
tion
Does
the
publ
ic kn
ow
abou
t CFP
B an
d ho
w to
fin
d th
e bu
reau
?
CFPB
has
mad
e a
cons
cious
effo
rt to
eng
age
the
publ
ic in
the
work
per
form
ed b
y th
e CF
PB.
Whi
le s
ucce
ss is
di
fficul
t to
defin
e at
this
early
sta
ge, C
FPB
has
an
enga
ged
com
mun
ity a
ctive
ly ut
ilizin
g th
e we
bsite
, and
the
bure
au im
pres
sivel
y re
ceive
d ov
er 1
0,00
0 co
nsum
er
resp
onse
s fro
m th
e fir
st ite
ratio
n of
Kno
w Be
fore
You
O
we. I
t is im
porta
nt to
not
e th
at C
FPB
cons
cious
ly ch
ose
not t
o do
a la
rge
rollo
ut in
Jul
y an
d th
ey c
aref
ully
weig
hed
the
trade
off b
etwe
en p
rovid
ing
early
awa
rene
ss b
ut n
ot
bein
g ab
le to
del
iver o
n ce
rtain
pro
mise
s an
d wa
iting
until
CFPB
has
the
capa
city,
bot
h pe
rson
nel w
ise a
nd
stat
utor
ily, t
o de
liver
on
prom
ises
mad
e.
Med
ium
• M
akin
g th
e pu
blic
awar
e of
the
CFPB
is a
size
able
task
and
thus
, it h
as
just
beg
un to
scr
atch
the
surfa
ce in
this
area
. W
e do
not
hav
e an
y re
com
men
datio
ns a
t thi
s tim
e be
yond
wha
t the
CFP
B is
alre
ady
doin
g in
th
is ar
ea. H
owev
er, t
he C
FPB
shou
ld c
onsid
er m
akin
g pu
blic
the
man
y wa
ys it
tries
to re
ach
the
publ
ic an
d as
k fo
r new
s wa
ys it
shou
ld c
onsid
er
via th
e we
bsite
, soc
ial m
edia
, etc
.
Com
mun
ity B
anke
rs fr
om
all 5
0 St
ates
Even
bef
ore
the
offic
ial o
peni
ng d
ate
of C
FPB,
the
bure
au
set a
n am
bitio
us g
oal fo
r mee
ting
with
com
mun
ity
bank
ers
from
all 5
0 st
ates
. Th
e go
al w
as m
ade
publ
ic via
th
e CF
PB’s
webs
ite, h
oldi
ng C
FPB
acco
unta
ble
to th
e pu
blic.
By
reac
hing
out
dire
ctly
and
thro
ugh
third
par
ty
grou
ps s
uch
as th
e IC
BA a
nd A
BA, C
FPB
was
able
to
mee
t the
ir go
al. T
he c
omm
unity
ban
kers
are
an
impo
rtant
gr
oup
for C
FPB
to e
ngag
e as
they
hav
e di
ffere
nt n
eeds
th
an th
e la
rger
par
ticip
ants
do.
If e
ngag
ed p
rope
rly, t
hey
coul
d se
rve
as a
n ad
voca
te fo
r the
CFP
B’s
work
ove
r tim
e.
High
•
No re
com
men
datio
ns p
rovid
ed fo
r thi
s pe
rform
ance
ele
men
t
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
109
Section 6: Budget
6.1 Scope of Audit
This section establishes the scope of our performance audit in the Budget area. The purpose of this assessment was to evaluate the CFPB’s budgeting processes and their strategic use of the budget, and to make recommendations on how these practices could be more effective and efficient for the organization. In order to evaluate CFPB’s performance, we examined the extent to which the bureau has: (1) complied with relevant laws and regulations; (2) achieved organizational goals and objectives; and (3) aligned with performance standards and best practices. In order to evaluate CFPB’s performance against relevant laws and regulations, we examined the extent to which the bureau has complied with applicable sections of the Dodd-Frank Act, as amended by the Full-Year Continuing Appropriations Act of 2011. In particular, we focused on the following areas:
Applicable language under Title X of the Dodd-Frank Act in order to understand the mechanism by which CFPB requests funding from and is funded by the Board of Governors of the Federal Reserve System
CFPB’s budget formulation and operations planning process including the parties involved; the processes, methods and tools being used; and the timing of budgeting processes
CFPB’s budget execution process including the tracking and reporting of commitments and outlays as well as the related set of reporting responsibilities
CFPB’s financial management systems, the preparation of the bureau financial statements and related assertion as to the effectiveness of internal controls, and planned financial audit of the bureau by the GAO
In order to assess achievement of organizational goals, we held a series of meetings with CFPB officials in the Office of the Chief Operating Officer and the Office of the Chief Financial Officer. In addition, we reviewed documents provided by CFPB related to strategic and operational planning, budget formulation and execution, budgeting policies and procedures, contractual agreements, funding requests of and transfers from the Federal Reserve, and expenditure analysis. We also evaluated whether CFPB budget execution activities provide effective and timely communication to appropriate parties within CFPB management and the public.
With respect to performance standards and best practices for budgeting, financial management and performance management, we principally referenced the guidance in OMB Circular A-11 Preparation, Submission, and Execution of the Budget; OMB Circular A-136, Financial Reporting Requirements; and OMB Circular A-123, Management’s Responsibility for Internal Control. We also referenced the Government Performance and Results Act (GPRA) Modernization Act of 2010 (Public Law 111-352 or GPRA-MA). While it has not been established that all of these standards apply to the CFPB, they are instructive as examples of federal budgeting standards.
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
110
Finally, taking into consideration the early stage in the evolution of CFPB, we gathered information from budget formulation and execution officials at two relevant organizations: (1) the Office of the Comptroller of the Currency (OCC); and (2) the Federal Deposit Insurance Corporation (FDIC). We also contacted the Administrative Resource Center of the Bureau of the Public Debt to arrange a demonstration of their budget formulation and performance management solution. Our objective was to gather experiences, ideas, and recommendations from these agencies to offer to CFPB to further refine and improve its budgeting processes.
6.2 Evaluation Criteria
The purpose of this section is to describe the evaluation criteria for this review area (associated findings and recommendations are presented in Section 6.3). As with other areas of performance, our audit focuses on three sets of criteria: (1) compliance with legal requirements; (2) achievement of organizational goals; and (3) alignment with performance standards, best practices, and/or benchmarks.
6.2.1 Compliance with the Law
The bullets below describe specific provisions of the Dodd-Frank Act that establish requirements and/or evaluation criteria in the Budget area.
Sections 1017(a)(1) and (3) of the Dodd-Frank Act specify the process by which the bureau requests funding from the Board of Governors based on amounts determined by the Director to be reasonably necessary to carry out the authorities of the bureau.
Section 1017(a)(2) of the Dodd-Frank Act specifies the annual funding cap for the bureau
amounting to a fixed percentage of the total operating expenses of the Federal Reserve System. Further, this section specifies that the funds derived from the Federal Reserve System shall not be subject to review by the Committees on Appropriations of the House of Representatives and the Senate.
Section 1017(a)(4) of the Dodd-Frank Act requires CFPB to provide OMB with copies of the bureau’s financial operating plans and forecasts as well as copies of the quarterly reports of the financial condition and results of operations of the bureau. CFPB is required to prepare annual financial statements; implement and maintain financial management systems that comply substantially with Federal financial management systems requirements and applicable Federal accounting standards; and provide to the Comptroller General of the United States an assertion as to the effectiveness of the internal controls that apply to financial reporting by the bureau, using the standards established in section 3512(c) of title 31, United States Code. The CFPB financial statements shall not be consolidated with the financial statements of either the Board of Governors or the Federal Reserve System.
Section 1017(a)(5) of the Dodd-Frank Act specifies the Comptroller General shall annually audit the financial transactions of the bureau in accordance with the United States generally accepted government auditing standards and submit to the Congress a report of each annual
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
111
audit conducted under this subsection. A copy of each audit report shall also be furnished to the President and to the bureau at the time submitted to the Congress.
Section 1017(b) of the Dodd-Frank Act requires the Federal Reserve to establish a separate CFPB fund—maintained and established at a Federal Reserve bank—where all amounts transferred to the bureau shall be deposited.
Section 1017(e) of the Dodd-Frank Act authorizes the bureau Director to determine whether the funds set aside from the Federal Reserve System are sufficient to carry out the authorities of the bureau. If it is determined that the funds are insufficient, the Director shall prepare a report regarding the extent to which the funding needs are anticipated to exceed the funded amount. Based on this report, the bureau may request appropriations up to $200 million per year for fiscal years 2012 through 2014.
6.2.2 Achievement of Organizational Goals
In order to assess achievement of organizational goals, we evaluated the progress that CFPB has made towards measurable goals that are documented in CFPB planning artifacts. The bullets below describe the specific organizational goals that are included in our analysis. In additional to our experiences with other comparable organizations, these goals were informed by our industry experiences, as well as case studies presented in GAO-03-669: Results-Oriented Cultures; Implementation Steps to Assist Mergers and Organizational Transformations (July 2003) and the Booz, Allen, Hamilton report to Treasury: Research & Analysis: Organizational Stand-ups Lessons Learned and Key Insights (May 2010).
Budget formulation and execution documentation reflects the overall organizational strategy.
Budget organization is set up to effectively meet the goals of CFPB.
Budget is formulated in a structured, comprehensive and useful manner.
Budget execution provides effective and timely communication to appropriate parties within CFPB management and the public.
Budget formulation and execution tools and reporting methods effectively support the needs of CFPB.
6.2.3 Alignment with Performance Standards and Best Practices
In order to assess achievement of performance standards and best practices, we evaluated the progress CFPB has made against two principal reference bases: (1) relevant OMB Circulars and Acts pertaining to budgeting, financial and performance management; and (2) other relevant U.S. federal agencies that have unique funding mechanisms and missions similar to that of CFPB.
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
112
Relevant OMB Circulars and Acts With respect to government wide budgeting, financial and performance management standards, we referenced OMB Circular A-11 Preparation, Submission, and Execution of the Budget; OMB Circular A-136, Financial Reporting Requirements; and OMB Circular A-123, Management’s Responsibility for Internal Control. We also referenced the Government Performance and Results Act (GPRA) Modernization Act of 2010 (Public Law 111-352 or GPRA-MA or the “Acts”).
OMB Circular A-11 maps out the basic budget policies that need to be followed and applicable laws, as well as the apportionment process and reporting requirements. Additionally, Circular A-11 provides a framework for strategic planning and performance monitoring.
OMB A-136 provides a reference for financial reporting guidance to Executive Branch departments, agencies, and entities required to submit audited financial statements, interim financial statements, and Performance and Accountability Reports.
OMB A-123 provides guidance to Federal managers on improving the accountability and effectiveness of Federal programs and operations by establishing, assessing, correcting, and reporting on internal control.
GPRA-MA creates a new government-wide planning and reporting framework and revises agency planning and reporting responsibilities. These guidelines include refined content requirements for strategic plans and priority goals, performance management plans, quarterly progress reviews, and performance reporting.
CFPB is currently working to clarify and document the applicability of these Circulars and Acts to CFPB operations. Meanwhile, the ASR team used these references as guiding principles and best practices sources for CFPB to use as its operations are stood up and established. The bullets below describe the specific performance standards that were included in our analysis.
Strategic Planning and Performance Management’s Relationship to Resource Allocation. We would expect evidence of progressive stages of strategic planning, as well as incorporation of GPRA-MA concepts that outline high-level organizational priorities, annual performance management plans, performance objectives and associated budget plans, progress reviews, accountability assignments, and plans for transparent monitoring and reporting.
Fund Control Administration. We would expect written policies that outline protocols for funding requests and transfers as well as procedural documentation related to internal control activities.
Budget Control / Execution and Reporting. We would expect documentation related to funds management that clearly identifies how the organization tracks commitments and obligations, along with identification of who within the organization is responsible for committing and obligating funds and levels of approval required. We would also expect
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
113
internal control procedural documentation related to budget control / execution and reporting activities.
Budgeting Processes for Relevant U.S. Federal Agencies
With respect to other relevant U.S. federal agencies with missions similar to CFPB’s and non-appropriated funding, we used outreach discussions with FDIC and OCC to gather information related to their current budget formulation processes and practices and how these might apply to CFPB. In addition, we contacted the Administrative Resource Center of the Bureau of the Public Debt to arrange a demonstration of the Budget Formulation & Execution Manager (BFEM) solution currently offered for budgeting and performance management automation. Our objective was to learn from the experiences, ideas, and recommendations of these agencies, so that CFPB might further define and improve its budgeting process.
6.3 Findings and Recommendations
In this section, we present key findings and recommendations for each of the three sets of criteria included in the performance audit: (1) compliance with the legal requirements; (2) achievement of organizational goals; and (3) alignment with performance standards, best practices, and/or benchmarks. The supporting tables referenced throughout this section are presented at the end of the section.
6.3.1 Compliance with Legal Requirements
Table 28 presents our assessment of the CFPB’s compliance with legal requirements. Each row in this table corresponds to a specific legal requirement. For each requirement, we describe the progress that the bureau has demonstrated to date, along with any recommendations for future action. As documented in Table 28, all relevant budgeting requirements under Title X of the Dodd-Frank Act have been addressed by the bureau and we offer no specific recommendations. Overall, we found that CFPB practices are documented and consistently performed. The bullets below summarize the demonstrated performance that emerged from our analysis.
CFPB funding requests and transfers are under the funding cap. Quarterly funding transfers have been prepared and presented to the Federal Reserve. CFPB funding for FY 2010 and 2011 was approximately 3.6% of the 2009 operating budget of the Federal Reserve System. The initial FY 2012 budget submitted to OMB (and included in the President’s Budget) was approximately 6.6% of the 2009 operating budget of the Federal Reserve System. In all cases, these funding requests are substantially below the funding caps defined by Dodd-Frank Section 1017(a)(2).
CFPB has no plans for appropriations requests. CFPB funding through the Federal Reserve is not subject to the traditional formulation and review of the Congressional appropriations process. However, should the bureau Director determine a need for appropriated funds, he/she may prepare a report that illustrates how funding needs exceed those dollars that are set aside from the Federal Reserve System as specified under Dodd-Frank Section 1017(e). Such appropriations cannot exceed $200 million per year for the fiscal years 2010 through 2014. CFPB did not request an appropriation in either FY 2011 or 2012.
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
114
CFPB has met the requirements to provide financial results to OMB. CFPB has provided copies of its financial operating plans as well as budget execution reports to OMB. CFPB plans to provide its annual financial statements to OMB on or about November 15.
CFPB’s internal controls testing and the GAO financial audit are underway. CFPB has hired an Internal Control over Financial Reporting (ICFR) contractor to perform a risk assessment, develop test plans, and provide CFPB management with test results. CFPB plans to provide an Assertion of Internal Controls for FY 2011. Further, as required under Dodd-Frank Section 1017(a)(5), an engagement letter has been executed with GAO to conduct an independent financial statement audit for CFPB for FY 2011.
CFPB leverages the BPD Administrative Resource Center for financial management processing. CFPB financial management systems are centrally hosted by the BPD Administrative Resource Center, which meets the requirements under Dodd-Frank Section 1017(a)(4)(C).
6.3.2 Achievement of Organizational Goals
Table 29 presents our assessment of the CFPB’s achievement of organizational goals. Each row in this table corresponds to a specific organizational goal. For each goal, we describe the expected progress we believe CFPB should have made during the bureau’s stand-up implementation and since the transfer date, the progress that the bureau has demonstrated to date, along with recommendations for future action. The bullets below highlight our key findings and recommendations
CFPB should complete policy and procedural documentation. CFPB should continue its work underway to more-fully document policies related to critical aspects of the Federal Reserve funding request and transfer process. In addition, CFPB should continue to more-fully document policies related to budget formulation and execution / commitment control. Supplemental documentation should be developed to define detailed funding and budgetary procedures, roles and responsibilities, and performance management and monitoring practices.
CFPB should build a staffing plan for the budget organization. CFPB has been hiring additional budget staff over the past several months. As the bureau continues to expand its operations, we encourage the bureau to continue to reach out to other comparable U.S. federal agencies with unique funding mechanisms and missions similar to that of CFPB (e.g., FDIC and OCC) to garner ideas and recommendations for the structure and staffing levels of the budgeting operations.
CFPB should continue to expand transparency of funding and expenditures. As the CFPB grows, we expect the bureau will continue to expand the amount of information available to the public (e.g., operational plans, funding levels, expenditures, financial performance management against bureau priorities, and the like).
CFPB should increase automation of budget formulation and performance management. As is expected, much of CFPB’s budget formulation process is manual and leverages spreadsheets – some of which are quite large and complex. CFPB should continue comparative analysis with other similar agencies to evaluate options for enhanced budget
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
115
formulation and performance management automation. Where possible, we recommend leveraging pre-existing solutions to best serve the bureau at this stage of its evolution versus developing a bureau-specific solution.
6.3.3 Alignment with Performance Standards and Best Practices
Table 30 presents our assessment of the CFPB’s alignment with performance standards and best practices adapted from respective components of OMB Circulars A-11, A-136 and A-123 as well as GPRA-MA. For each aspect of performance, we provide the following information: (1) a rating of CFPB’s performance to date, using a stoplight scale (i.e., Red, Yellow or Green); (2) a summary of demonstrated performance; (3) the priority of future progress in this area, based on the importance of the performance area for a start-up organization; and (4) recommendations for future action. The bullets below highlight our key findings and recommendations.
CFPB should continue to clarify and document the applicability of budget-related Circulars and Acts. CFPB continues its efforts to clarify and document the applicability to CFPB operations of various budgeting and performance management Circulars and Acts. CFPB has already adopted and will continue to integrate into its operations the principles and concepts contained within the relevant Circulars and Acts and the bureau will implement, where possible, best practice components. We support the bureau’s plans to both document and implement all applicable standards and best practices.
CFPB should incorporate “outcome” objectives in strategic planning. We understand that bureau-wide strategic plans are under development within CFPB. While this performance audit did not evaluate the progress nor content of the current draft plans, we encourage CFPB’s progressive stages of strategic planning to incorporate GPRA-MA concepts outlining high-level organizational priorities, “outcome” objectives, annual performance management plans, relationship to funding and budgetary plans, progress review plans, accountability assignments, and plans for transparent monitoring and reporting.
CFPB should load its budget at a divisional level. Starting with the FY 2013 President’s Budget (currently being formulated) and the FY 2012 Operations Plan for CFPB, the bureau plans to construct its budget on a bottom-up basis by cost center. For the FY 2012 Operations Plan, CFPB plans to load its budget in its financial management system on a divisional basis for enhanced execution and control. We support the bureau’s plan to begin loading the budget at a divisional level in FY 2012 for more effective management, control and accountability.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
116
Tab
le 2
8: C
omp
lian
ce w
ith
Leg
al R
equ
irem
ents
Lega
l Req
uire
men
t De
mon
stra
ted
Perfo
rman
ce
Find
ing
/ Rec
omm
enda
tion
SEC.
101
7. F
UNDI
NG; P
ENAL
TIES
AND
FIN
ES.
(a) T
RANS
FER
OF
FUND
S FR
OM
BO
ARD
OF
GO
VERN
ORS
.—
(1) I
N G
ENER
AL.—
Each
year
(or q
uarte
r of s
uch
year
), be
ginn
ing o
n th
e de
signa
ted
trans
fer d
ate,
and
eac
h qu
arte
r th
erea
fter,
the
Boar
d of
Gov
erno
rs s
hall t
rans
fer t
o th
e Bu
reau
from
the
com
bine
d ea
rnin
gs o
f the
Fed
eral
Res
erve
Sys
tem
, the
am
ount
det
erm
ined
by t
he D
irect
or to
be
reas
onab
ly ne
cess
ary
to ca
rry o
ut th
e au
thor
ities o
f the
Bur
eau
unde
r Fed
eral
cons
umer
fin
ancia
l law,
takin
g in
to a
ccou
nt s
uch
othe
r sum
s m
ade
avai
labl
e to
the
Bure
au fr
om th
e pr
eced
ing ye
ar (o
r qua
rter o
f suc
h ye
ar).
• Do
cum
ente
d bu
dget
fund
ing
proc
ess.
• Fe
dera
l Res
erve
acc
ount
ser
vices
ag
reem
ent.
• Fo
rmal
app
rove
d tra
nsfe
r req
uest
s.
• Fu
ndin
g tra
nsfe
rs b
egan
08/
10/2
010.
CFPB
pla
ns a
re d
ocum
ente
d an
d pr
oces
ses
are
cons
isten
tly
perfo
rmed
.
(2) F
UNDI
NG C
AP.—
(A) I
N G
ENER
AL.—
Notw
ithst
andi
ng p
arag
raph
(1),
and
in a
ccor
danc
e wi
th th
is pa
ragr
aph,
the
amou
nt th
at s
hall b
e tra
nsfe
rred
to
the
Bure
au in
eac
h fis
cal y
ear s
hall n
ot e
xcee
d a
fixed
per
cent
age
of th
e to
tal o
pera
ting
expe
nses
of t
he F
eder
al R
eser
ve S
yste
m,
as re
porte
d in
the
Annu
al R
epor
t, 20
09, o
f the
Boa
rd o
f Gov
erno
rs, e
qual
to—
(i) 1
0 pe
rcen
t of s
uch
expe
nses
in fis
cal y
ear 2
011;
(ii) 1
1 pe
rcen
t of s
uch
expe
nses
in fis
cal y
ear 2
012;
and
(iii) 1
2 pe
rcen
t of s
uch
expe
nses
in fis
cal y
ear 2
013,
and
in e
ach
year
ther
eafte
r.
(B) A
DJUS
TMEN
T O
F AM
OUN
T.—
The
dolla
r am
ount
refe
rred
to in
subp
arag
raph
(A)(i
ii) sh
all b
e ad
juste
d H.
R. 4
173—
601
annu
ally,
usin
g th
e pe
rcen
t incr
ease
, if a
ny, in
the
empl
oym
ent c
ost in
dex
for t
otal
com
pens
atio
n fo
r Sta
te a
nd lo
cal g
over
nmen
t wo
rker
s pub
lishe
d by
the
Fede
ral G
over
nmen
t, or
the
succ
esso
r ind
ex th
eret
o, fo
r the
12-
mon
th p
erio
d en
ding
on
Sept
embe
r 30
of th
e ye
ar p
rece
ding
the
trans
fer.
(C) R
EVIE
WAB
ILIT
Y.—
Notw
ithst
andi
ng a
ny o
ther
pro
vision
in th
is titl
e, th
e fu
nds
deriv
ed fr
om th
e Fe
dera
l Res
erve
Sys
tem
pu
rsua
nt to
this
subs
ectio
n sh
all n
ot b
e su
bject
to re
view
by th
e Co
mm
ittees
on
Appr
opria
tions
of t
he H
ouse
of R
epre
sent
ative
s an
d th
e Se
nate
.
• Pe
r CFP
B, a
ctua
l fund
ing
prov
ided
for F
Y 20
10 a
nd 2
011
has
reac
hed
appr
oxim
atel
y 3.
6% o
f the
Fed
eral
Re
serv
e’s
2009
ope
ratin
g bu
dget
.
• CF
PB's
initia
l FY
2012
bud
get s
ubm
itted
to O
MB
(and
inclu
ded
in th
e Pr
esid
ent's
Bu
dget
) is
appr
oxim
atel
y 6.
6% o
f the
Fe
dera
l Res
erve
's 20
09 o
pera
ting
budg
et.
CFPB
pla
ns a
re d
ocum
ente
d an
d pr
oces
ses
are
cons
isten
tly
perfo
rmed
.
(3) T
RANS
ITIO
N PE
RIO
D.—
Begi
nning
on
the
date
of e
nactm
ent o
f thi
s Ac
t and
unt
il the
des
igna
ted
trans
fer d
ate,
the
Boar
d of
Gov
erno
rs s
hall t
rans
fer t
o th
e Bu
reau
the
amou
nt e
stim
ated
by
the
Secr
etar
y ne
eded
to ca
rry o
ut th
e au
thor
ities
gran
ted
to th
e Bu
reau
und
er F
eder
al co
nsum
er fin
ancia
l law,
from
the
date
of e
nact
men
t of t
his
Act u
ntil t
he d
esig
nate
d tra
nsfe
r dat
e.
• Do
cum
ente
d bu
dget
fund
ing
proc
ess.
• Fo
rmal
app
rove
d tra
nsfe
r req
uest
s.
• Bu
dget
exe
cutio
n tra
ckin
g an
d st
atus
re
porti
ng.
CFPB
pla
ns a
re d
ocum
ente
d an
d pr
oces
ses
are
cons
isten
tly
perfo
rmed
.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
117
Lega
l Req
uire
men
t De
mon
stra
ted
Perfo
rman
ce
Find
ing
/ Rec
omm
enda
tion
(4) B
UDG
ET A
ND F
INAN
CIAL
MAN
AGEM
ENT.
—
(A) F
INAN
CIAL
OPE
RATI
NG P
LANS
AND
FO
RECA
STS.
—Th
e Di
rect
or s
hall p
rovid
e to
the
Dire
ctor
of t
he O
ffice
of
Man
agem
ent a
nd B
udge
t cop
ies o
f the
finan
cial o
pera
ting
plan
s an
d fo
reca
sts
of th
e Di
rect
or, a
s pr
epar
ed b
y th
e Di
rect
or in
the
ordi
nary
cour
se o
f the
ope
ratio
ns o
f the
Bur
eau,
and
copie
s of
the
quar
terly
repo
rts o
f the
finan
cial c
ondi
tion
and
resu
lts o
f op
erat
ions
of t
he B
urea
u, a
s pr
epar
ed b
y th
e Di
rect
or in
the
ordi
nary
cou
rse
of th
e op
erat
ions
of th
e Bu
reau
.
(B) F
INAN
CIAL
STA
TEM
ENTS
.—Th
e Bu
reau
sha
ll pre
pare
ann
ually
a s
tate
men
t of—
(i) a
sset
s an
d lia
biliti
es a
nd s
urpl
us o
r def
icit;
(ii) in
com
e an
d ex
pens
es; a
nd
(iii) s
ourc
es a
nd a
pplic
atio
n of
fund
s.
(C) F
INAN
CIAL
MAN
AGEM
ENT
SYST
EMS.
— T
he B
urea
u sh
all im
plem
ent a
nd m
aint
ain
finan
cial m
anag
emen
t sys
tem
s th
at
com
ply s
ubst
antia
lly w
ith F
eder
al fin
ancia
l man
agem
ent s
yste
ms
requ
irem
ents
and
app
licab
le F
eder
al a
ccou
ntin
g st
anda
rds.
(D) A
SSER
TIO
N O
F IN
TERN
AL C
ONT
ROLS
.— T
he D
irect
or sh
all p
rovid
e to
the
Com
ptro
ller G
ener
al o
f the
Uni
ted
Stat
es a
n as
serti
on a
s to
the
effe
ctive
ness
of t
he in
tern
al c
ontro
ls th
at a
pply
to fin
ancia
l rep
ortin
g by
the
Bure
au, u
sing
the
stand
ards
es
tabl
ished
in s
ectio
n 35
12(c
) of t
itle 3
1, U
nite
d St
ates
Cod
e.
(E) R
ULE
OF
CONS
TRUC
TIO
N.—
This
subs
ectio
n m
ay n
ot b
e co
nstru
ed a
s im
plyin
g an
y ob
ligat
ion
on th
e pa
rt of
the
Dire
ctor
to
cons
ult w
ith o
r obt
ain
the
cons
ent o
r app
rova
l of t
he D
irect
or o
f the
Offic
e of
Man
agem
ent a
nd B
udge
t with
resp
ect t
o an
y re
port,
pl
an, f
orec
ast,
or o
ther
info
rmat
ion
refe
rred
to in
sub
para
grap
h (A
) or a
ny ju
risdic
tion
or o
vers
ight
ove
r the
affa
irs o
r ope
ratio
ns o
f th
e Bu
reau
.
(F) F
INAN
CIAL
STA
TEM
ENTS
.—Th
e fin
ancia
l sta
tem
ents
of t
he B
urea
u sh
all n
ot b
e co
nsol
idat
ed w
ith th
e fin
ancia
l sta
tem
ents
of e
ither
the
Boar
d of
Gov
erno
rs o
r the
Fed
eral
Res
erve
Sys
tem
.
• Co
pies
of f
inan
cial o
pera
ting
plan
s pr
ovid
ed to
OM
B.
• Co
pies
of b
udge
t exe
cutio
n re
ports
pr
ovid
ed to
OM
B.
• An
nual
finan
cial s
tate
men
ts p
lann
ed to
be
sha
red
with
OM
B on
or a
bout
No
vem
ber 1
5.
• Th
e CF
PB fin
ancia
l sta
tem
ents
hav
e ne
ver b
een
cons
olid
ated
with
eith
er th
e De
partm
ent o
f the
Tre
asur
y, th
e Bo
ard
of
Gov
erno
rs o
f the
Fed
eral
, or t
he F
eder
al
Rese
rve
Syst
em.
• Im
plem
ente
d Fi
nanc
ial M
anag
emen
t sy
stem
sui
te h
oste
d by
Tre
asur
y BP
D –
Adm
inist
rativ
e Re
sour
ce C
ente
r.
• CF
PB h
ired
an In
tern
al C
ontro
l Ove
r Fi
nanc
ial R
epor
ting
(ICFR
) con
tract
or to
pe
rform
a ri
sk a
sses
smen
t, de
velo
p te
st
plan
s, a
nd p
rovid
e CF
PB m
anag
emen
t wi
th te
st re
sults
.
• CF
PB p
lans
to p
rovid
e an
Ass
ertio
n of
In
tern
al C
ontro
ls fo
r FY
2011
.
CFPB
pla
ns a
re d
ocum
ente
d an
d pr
oces
ses
are
cons
isten
tly
perfo
rmed
.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
118
Lega
l Req
uire
men
t De
mon
stra
ted
Perfo
rman
ce
Find
ing
/ Rec
omm
enda
tion
(5) A
UDIT
OF
THE
BURE
AU.—
H. R
. 417
3—60
2
(A) I
N G
ENER
AL.—
The
Com
ptro
ller G
ener
al s
hall a
nnua
lly a
udit t
he fin
ancia
l tran
sact
ions
of t
he B
urea
u in
acc
orda
nce
with
the
Unite
d St
ates
gen
eral
ly ac
cept
ed g
over
nmen
t aud
iting
stan
dard
s, a
s m
ay b
e pr
escr
ibed
by
the
Com
ptro
ller G
ener
al o
f the
Uni
ted
Stat
es. T
he a
udit s
hall b
e co
nduc
ted
at th
e pla
ce o
r pla
ces
wher
e ac
coun
ts o
f the
Bur
eau
are
norm
ally
kept
. The
repr
esen
tativ
es
of th
e G
over
nmen
t Acc
ount
abilit
y O
ffice
shal
l hav
e ac
cess
to th
e pe
rson
nel a
nd to
all b
ooks
, acc
ount
s, d
ocum
ents
, pap
ers,
re
cord
s (in
cludin
g el
ectro
nic
reco
rds)
, rep
orts
, file
s, a
nd a
ll oth
er p
aper
s, a
utom
ated
dat
a, th
ings
, or p
rope
rty b
elon
ging
to o
r und
er
the
cont
rol o
f or u
sed
or e
mpl
oyed
by
the
Bure
au p
erta
inin
g to
its fin
ancia
l tran
sacti
ons
and
nece
ssar
y to
facil
itate
the
audi
t, an
d su
ch re
pres
enta
tives
shal
l be
affo
rded
full f
acilit
ies
for v
erify
ing
trans
actio
ns w
ith th
e ba
lance
s or
sec
uritie
s he
ld b
y dep
osito
ries,
fis
cal a
gent
s, a
nd cu
stodi
ans.
All s
uch
book
s, a
ccou
nts,
doc
umen
ts, re
cord
s, re
ports
, file
s, p
aper
s, a
nd p
rope
rty o
f the
Bur
eau
shal
l rem
ain in
pos
sess
ion
and
cust
ody
of th
e Bu
reau
. The
Com
ptro
ller G
ener
al m
ay o
btain
and
dup
licat
e an
y su
ch b
ooks
, ac
coun
ts, d
ocum
ents
, rec
ords
, wor
king
pape
rs, a
utom
ated
dat
a an
d file
s, o
r oth
er in
form
atio
n re
leva
nt to
suc
h au
dit w
ithou
t cos
t to
the
Com
ptro
ller G
ener
al, a
nd th
e rig
ht o
f acc
ess
of th
e Co
mpt
rolle
r Gen
eral
to s
uch
info
rmat
ion
shal
l be
enfo
rcea
ble
purs
uant
to
sec
tion
716(
c) o
f title
31,
Uni
ted
Stat
es C
ode.
(B) R
EPO
RT.—
The
Com
ptro
ller G
ener
al s
hall s
ubm
it to
the
Cong
ress
a re
port
of e
ach
annu
al a
udit c
ondu
cted
und
er th
is su
bsec
tion.
The
repo
rt to
the
Cong
ress
sha
ll set
forth
the
scop
e of
the
audi
t and
sha
ll inc
lude
the
stat
emen
t of a
sset
s an
d lia
biliti
es
and
surp
lus
or d
efici
t, th
e st
atem
ent o
f inco
me
and
expe
nses
, the
sta
tem
ent o
f sou
rces
and
app
licat
ion
of fu
nds,
and
such
co
mm
ents
and
info
rmat
ion
as m
ay b
e de
emed
nec
essa
ry to
info
rm C
ongr
ess
of th
e fin
ancia
l ope
ratio
ns a
nd co
nditio
n of
the
Bure
au, t
oget
her w
ith su
ch re
com
men
datio
ns w
ith re
spec
t the
reto
as
the
Com
ptro
ller G
ener
al m
ay d
eem
adv
isabl
e. A
cop
y of
ea
ch re
port
shal
l be
furn
ished
to th
e Pr
esid
ent a
nd to
the
Bure
au a
t the
time
subm
itted
to th
e Co
ngre
ss.
(C) A
SSIS
TANC
E AN
D CO
STS.
—Fo
r the
pur
pose
of c
ondu
ctin
g an
aud
it und
er th
is su
bsec
tion,
the
Com
ptro
ller G
ener
al m
ay, in
th
e di
scre
tion
of th
e Co
mpt
rolle
r Gen
eral
, em
ploy
by
cont
ract
, with
out r
egar
d to
sect
ion
3709
of t
he R
evise
d St
atut
es o
f the
Uni
ted
Stat
es (4
1 U.
S.C.
5),
prof
essio
nal s
ervic
es o
f firm
s an
d or
gani
zatio
ns o
f cer
tified
pub
lic a
ccou
ntan
ts fo
r tem
pora
ry p
erio
ds o
r for
sp
ecia
l pur
pose
s. U
pon
the
requ
est o
f the
Com
ptro
ller G
ener
al, t
he D
irect
or o
f the
Bur
eau
shal
l tran
sfer t
o th
e G
over
nmen
t Ac
coun
tabi
lity O
ffice
from
fund
s av
aila
ble,
the
amou
nt re
ques
ted
by th
e Co
mpt
rolle
r Gen
eral
to c
over
the
full c
osts
of a
ny a
udit
and
repo
rt co
nduc
ted
by th
e Co
mpt
rolle
r Gen
eral
. The
Com
ptro
ller G
ener
al sh
all c
redi
t fun
ds tr
ansf
erre
d to
the
acco
unt
esta
blish
ed fo
r sal
arie
s and
exp
ense
s of
the
Gov
ernm
ent A
ccou
ntab
ility
Offic
e, a
nd s
uch
amou
nt s
hall b
e av
ailab
le u
pon
rece
ipt
and
with
out f
iscal
year
limita
tion
to c
over
the
full c
osts
of t
he a
udit a
nd re
port.
• An
eng
agem
ent le
tter h
as b
een
exec
uted
wi
th th
e G
AO to
con
duct
an
inde
pend
ent
finan
cial s
tate
men
t aud
it for
CFP
B fo
r FY
2011
.
• Th
e sc
ope
of th
e G
AO e
ngag
emen
t lette
r ad
dres
ses
the
requ
irem
ents
of t
he
legi
slatio
n.
CFPB
pla
ns a
re d
ocum
ente
d an
d pr
oces
ses
are
cons
isten
tly
perfo
rmed
.
(b) C
ONS
UMER
FIN
ANCI
AL P
ROTE
CTIO
N FU
ND.—
H. R
. 417
3—60
3
(1) S
EPAR
ATE
FUND
IN F
EDER
AL R
ESER
VE E
STAB
LISH
ED.—
Ther
e is
esta
blish
ed in
the
Fede
ral R
eser
ve a
sep
arat
e fu
nd, t
o be
know
n as
the
‘‘Bur
eau
of C
onsu
mer
Fin
ancia
l Pro
tect
ion
Fund
’’ (re
ferre
d to
in th
is se
ctio
n as
the
‘‘Bur
eau
Fund
’’). T
he B
urea
u Fu
nd sh
all b
e m
aint
aine
d an
d es
tabl
ished
at a
Fed
eral
rese
rve
bank
, in a
ccor
danc
e wi
th s
uch
requ
irem
ents
as
the
Boar
d of
Gov
erno
rs m
ay im
pose
.
(2) F
UND
RECE
IPTS
.—Al
l am
ount
s tra
nsfe
rred
to th
e Bu
reau
und
er s
ubse
ctio
n (a
) sha
ll be
depo
sited
into
the
Bure
au F
und.
• Do
cum
ente
d bu
dget
fund
ing
proc
ess.
• Fe
dera
l Res
erve
acc
ount
ser
vices
ag
reem
ent.
• A
sepa
rate
fund
has
bee
n es
tabl
ished
at
the
Fede
ral R
eser
ve fo
r CFP
B an
d al
l am
ount
s tra
nsfe
rred
by th
e Fe
dera
l Re
serv
e ha
ve b
een
depo
sited
into
the
sepa
rate
CFP
B fu
nd.
CFPB
pla
ns a
re d
ocum
ente
d an
d pr
oces
ses
are
cons
isten
tly
perfo
rmed
.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
119
Lega
l Req
uire
men
t De
mon
stra
ted
Perfo
rman
ce
Find
ing
/ Rec
omm
enda
tion
(e) A
UTHO
RIZA
TIO
N O
F AP
PRO
PRIA
TIO
NS; A
NNUA
L RE
PORT
.—
(1) D
ETER
MIN
ATIO
N RE
GAR
DING
NEE
D FO
R AP
PRO
PRIA
TED
FUND
S.—
(A)
IN G
ENER
AL.—
The
Dire
ctor
is a
utho
rized
to d
eter
min
e th
at s
ums
avai
lable
to th
e Bu
reau
und
er th
is se
ctio
n wi
ll no
t be
suffic
ient
to ca
rry o
ut th
e au
thor
ities
of th
e Bu
reau
und
er F
eder
al co
nsum
er fin
ancia
l law
for t
he u
pcom
ing
year
.
(B) R
EPO
RT R
EQUI
RED.
—W
hen
mak
ing
a de
term
inat
ion
unde
r sub
para
grap
h (A
), th
e Di
rect
or s
hall p
repa
re a
repo
rt re
gard
ing
the
fund
ing
of th
e Bu
reau
, inc
ludin
g th
e as
sets
and
liab
ilitie
s of
the
Bure
au, a
nd th
e ex
tent
to w
hich
the
fund
ing
need
s of
the
Bure
au a
re a
ntici
pate
d to
exc
eed
the
leve
l of t
he a
mou
nt s
et fo
rth in
sub
sect
ion
(a)(2
). Th
e Di
rect
or s
hall s
ubm
it th
e re
port
to th
e Pr
esid
ent
and
to t
he C
omm
ittee
on A
ppro
pria
tions
of
the
Sena
te a
nd t
he C
omm
ittee
on A
ppro
pria
tions
of
the
Hous
e of
Re
pres
enta
tives
.
(2)
AUTH
ORI
ZATI
ON
OF
APPR
OPR
IATI
ONS
.—If
the
Dire
ctor
mak
es th
e de
term
inat
ion
and
subm
its th
e re
port
purs
uant
to
para
grap
h (1
), th
ere
are
here
by a
utho
rized
to b
e ap
prop
riate
d to
the
Bure
au, f
or th
e pu
rpos
es o
f car
ryin
g ou
t the
aut
horit
ies
gran
ted
in F
eder
al c
onsu
mer
finan
cial la
w, $
200,
000,
000
for e
ach
of fis
cal y
ears
201
0, 2
011,
201
2, 2
013,
and
201
4.
(3)
APPO
RTIO
NMEN
T.—
Notw
ithst
andi
ng a
ny o
ther
pro
visio
n of
law
, th
e am
ount
s in
par
agra
ph (
2) s
hall
be s
ubje
ct t
o ap
porti
onm
ent u
nder
sec
tion
1517
of t
itle 3
1, U
nite
d St
ates
Cod
e, a
nd re
stric
tions
that
gen
eral
ly ap
ply to
the
use
of a
ppro
pria
ted
fund
s in
title
31,
Uni
ted
Stat
es C
ode,
and
oth
er la
ws.
(4) A
NNUA
L RE
PORT
.—Th
e Di
rect
or s
hall p
repa
re a
nd s
ubm
it a re
port,
on
an a
nnua
l bas
is, to
the
Com
mitte
e on
App
ropr
iatio
ns
of th
e Se
nate
and
the
Com
mitte
e on
App
ropr
iatio
ns o
f the
Hou
se o
f Rep
rese
ntat
ives
rega
rdin
g th
e fin
ancia
l ope
ratin
g pla
ns a
nd
fore
cast
s of
the
Dire
ctor,
the
finan
cial c
ondi
tion
and
resu
lts o
f ope
ratio
ns o
f the
Bur
eau,
and
the
sour
ces
and
appl
icatio
n of
fund
s of
the
Bure
au, in
cludin
g an
y fu
nds a
ppro
pria
ted
in a
ccor
danc
e wi
th th
is su
bsec
tion.
• CF
PB is
not
pla
nnin
g to
requ
est a
n ap
prop
riatio
n in
eith
er F
Y 20
11 o
r 201
2.
CFPB
pla
ns a
re d
ocum
ente
d an
d pr
oces
ses
are
cons
isten
tly
perfo
rmed
.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
120
Tab
le 2
9: A
chie
vem
ent
of O
rgan
izat
ion
al G
oals
Org
aniz
atio
nal G
oal
Expe
cted
Per
form
ance
De
mon
stra
ted
Perfo
rman
ce
Find
ing
/ Rec
omm
enda
tion
Budg
et fo
rmul
atio
n an
d ex
ecut
ion
docu
men
tatio
n re
flect
s th
e ov
eral
l or
gani
zatio
nal s
trate
gy
• O
rgan
izatio
nal s
trate
gies
and
“out
com
e”
obje
ctive
s pr
ovid
e di
rect
line-
of-s
ight
for
budg
et fo
rmul
atio
n an
d ex
ecut
ion
repo
rting
. •
Incr
ease
d as
socia
tion
of “o
utco
mes
” wi
th re
late
d sp
end.
• CF
PB is
in th
e pr
oces
s of
pre
parin
g a
stra
tegi
c pl
an.
• CF
PB h
as n
ot y
et b
egun
ass
ocia
ting
reso
urce
s wi
th “o
utco
mes
” or
perfo
rman
ce m
etric
s.
Refe
r to
com
men
ts in
Tab
le 3
0 un
der “
Stra
tegi
c Pl
anni
ng a
nd P
erfo
rman
ce M
anag
emen
t’s
Rela
tions
hip
to R
esou
rce
Allo
catio
ns.”
Budg
et o
rgan
izatio
n is
set u
p to
effe
ctive
ly m
eet t
he g
oals
of C
FPB
• Dr
aft o
rgan
izatio
nal a
nd s
taffin
g pl
an
unde
r rev
iew
for f
inal
app
rova
l. •
Draf
t hirin
g pl
ans
in p
lace
. •
Draf
t bud
get p
ositio
n de
scrip
tions
.
• Th
e bu
dget
offic
e re
ports
into
the
offic
e of
the
CFO
.
• Cu
rrent
ly th
ere
are
3 po
sitio
ns in
the
Budg
et O
ffice.
Eac
h of
thes
e in
divid
uals
brin
g sig
nific
ant b
udge
t exp
erie
nce
to
CFPB
.
• Po
tent
ial to
add
bud
get s
taff
in k
ey
depa
rtmen
ts, if
it is
deem
ed n
eces
sary
.
As th
e bu
reau
con
tinue
s to
exp
and
its
oper
atio
ns, w
e en
cour
age
the
bure
au to
co
ntin
ue to
reac
h ou
t to
othe
r com
para
ble
U.S.
fe
dera
l age
ncie
s wi
th u
niqu
e fu
ndin
g m
echa
nism
s an
d m
issio
ns s
imila
r to
that
of
CFPB
(e.g
., FD
IC a
nd O
CC) t
o ga
rner
idea
s an
d re
com
men
datio
ns fo
r the
stru
ctur
e an
d st
affin
g le
vels
of th
e bu
dget
ing
oper
atio
ns.
Budg
et is
form
ulat
ed in
a s
truct
ured
, co
mpr
ehen
sive
and
usef
ul m
anne
r
• Bu
dget
pol
icies
dra
fted
and
unde
r re
view
for a
ppro
val.
• Bu
dget
pro
cess
es fo
r for
mul
atio
n do
cum
ente
d an
d in
pla
ce.
• O
rgan
izatio
nal c
omm
unica
tion
has
been
pr
ovid
ed to
bot
h al
ert a
nd in
stru
ct
parti
cipan
ts in
the
budg
et fo
rmul
atio
n pr
oces
s.
• An
ann
ual O
pera
ting
Plan
is u
sed
to
synt
hesiz
e th
e bu
dget
form
ulat
ion
effo
rts.
• Be
nchm
arks
and
fore
cast
s ha
ve b
een
used
to b
uild
the
star
t-up
budg
ets
(esp
ecia
lly in
the
area
of w
orkf
orce
pl
anni
ng).
• Th
e fo
rmul
atio
n is
pres
ente
d to
ex
ecut
ive m
anag
emen
t for
revie
w,
revis
ion,
and
app
rova
l.
Refe
r to
com
men
ts in
Tab
le 3
0 un
der “
Budg
et
Cont
rol /
Exec
utio
n an
d Re
porti
ng.”
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
121
Org
aniz
atio
nal G
oal
Expe
cted
Per
form
ance
De
mon
stra
ted
Perfo
rman
ce
Find
ing
/ Rec
omm
enda
tion
Budg
et e
xecu
tion
prov
ides
effe
ctive
and
tim
ely
com
mun
icatio
n to
app
ropr
iate
pa
rties
with
in C
FPB
man
agem
ent a
nd th
e pu
blic
• Bu
dget
pro
cess
es fo
r exe
cutio
n an
d co
mm
itmen
t con
trol d
ocum
ente
d an
d in
pl
ace.
•
Inte
rnal
con
trols
docu
men
tatio
n dr
afte
d an
d un
der r
evie
w fo
r app
rova
l. •
Mon
thly
and
quar
terly
bud
get e
xecu
tion
repo
rting
per
form
ed.
• Bu
dget
exe
cutio
n re
sults
repo
rted
and
publ
ished
on
exte
rnal
web
sites
to
prom
ote
trans
pare
ncy.
• CF
PB h
as p
oste
d in
form
atio
n re
gard
ing
finan
cial in
form
atio
n on
line.
• D
ocum
ents
ava
ilabl
e in
clude
:
• CF
O u
pdat
es th
at s
umm
arize
sp
endi
ng to
dat
e;
• Bu
dget
in b
rief d
ocum
ents
;
• CF
PB b
udge
t for
FY
2011
su
bmitte
d to
OM
B
• Bu
dget
con
trol is
bei
ng m
onito
red
thro
ugh
bi-w
eekly
bud
get t
o ac
tual
re
ports
from
the
acco
untin
g sy
stem
.
• IC
FR ri
sk a
sses
smen
t and
con
trols
test
ing
has
begu
n le
vera
ging
con
tract
or
reso
urce
s.
CFPB
has
mad
e go
od p
rogr
ess
with
rega
rd to
tra
nspa
renc
y an
d co
mm
unica
tion,
bot
h in
tern
ally
as w
ell a
s ex
tern
ally.
As
thei
r bud
get
deta
il pro
gres
ses,
we
expe
ct th
at th
ey w
ill co
ntin
ue to
exp
and
the
amou
nt o
f info
rmat
ion
avai
labl
e to
the
publ
ic (e
.g.,
oper
atio
nal p
lans
, fu
ndin
g le
vels,
exp
endi
ture
s, p
erfo
rman
ce
man
agem
ent a
gain
st b
urea
u pr
iorit
ies)
.
Budg
et fo
rmul
atio
n an
d ex
ecut
ion
tool
s an
d re
porti
ng m
etho
ds e
ffect
ively
supp
ort t
he
need
s of
CFP
B
• Au
tom
ated
tool
s us
ed to
form
ulat
e th
e bu
dget
as
well a
s to
per
form
bud
get
exec
utio
n an
d co
mm
itmen
t con
trol.
• Dr
aft lo
ng-ra
nge
plan
s in
pla
ce fo
r co
mpr
ehen
sive
budg
et fo
rmul
atio
n an
d G
PRA-
MA
tool
(s).
• Bu
dget
form
ulat
ion
is pr
imar
ily d
one
on
spre
adsh
eets
.
• T
he b
urea
u lo
ads
the
budg
et a
t the
CF
PB le
vel c
urre
ntly,
but
pla
ns a
di
visio
nal le
vel lo
ad fo
r FY
2012
.
• C
FPB
uses
the
BPD
Fina
ncia
l M
anag
emen
t sys
tem
for b
udge
t ex
ecut
ion
and
com
mitm
ent c
ontro
l.
Muc
h of
this
proc
ess
is m
anua
l or l
ever
agin
g sp
read
shee
ts, w
hich
is e
xpec
ted.
CFP
B sh
ould
co
ntin
ue c
ompa
rativ
e an
alys
is wi
th o
ther
sim
ilar
agen
cies
to e
valu
ate
optio
ns fo
r enh
ance
d bu
dget
form
ulat
ion
and
perfo
rman
ce
man
agem
ent a
utom
atio
n.
Inde
pend
ent P
erfo
rman
ce A
udit
of C
FPB
Ope
ratio
ns a
nd B
udge
t O
ctob
er 1
5, 2
011
122
Tab
le 3
0: A
lign
men
t w
ith
Per
form
ance
Sta
nd
ard
s
Fact
or
Scor
e Su
mm
ary
of P
erfo
rman
ce
Prio
rity
Find
ing
/ Rec
omm
enda
tion
Stra
tegi
c Pl
anni
ng
and
Perfo
rman
ce
Man
agem
ent’s
Re
latio
nshi
p to
Re
sour
ce A
lloca
tions
CF
PB p
rovid
ed c
ompo
nent
-leve
l, dep
artm
enta
l pla
ns d
evel
oped
as
part
of th
e st
and-
up im
plem
enta
tion
activ
ities
and
also
use
d to
su
ppor
t the
FY
2012
Ope
ratio
ns P
lan
form
ulat
ion
CF
PB p
rovid
ed c
omm
unica
tions
and
pla
nnin
g do
cum
enta
tion
rela
ted
to its
cur
rent
stra
tegi
c pl
an d
evel
opm
ent e
fforts
Med
ium
Whi
le th
is pe
rform
ance
aud
it did
not
eva
luat
e th
e pr
ogre
ss n
or
cont
ent o
f the
cur
rent
dra
ft pl
ans,
we
enco
urag
e CF
PB’s
prog
ress
ive s
tage
s of
a s
trate
gic
plan
ning
pro
cess
to in
corp
orat
e G
PRA-
MA
conc
epts
out
linin
g hi
gh-le
vel o
rgan
izatio
nal p
riorit
ies,
“o
utco
me”
obj
ectiv
es, a
nnua
l per
form
ance
man
agem
ent p
lans
, re
latio
nshi
p to
fund
ing
and
budg
etar
y pl
ans,
pro
gres
s re
view
plan
s, a
ccou
ntab
ility
assig
nmen
ts, a
nd p
lans
for t
rans
pare
nt
mon
itorin
g an
d re
porti
ng.
Fund
Con
trol
Adm
inist
ratio
n
CF
PB d
emon
stra
ted
a re
peat
able
pro
cess
for p
repa
ring,
app
rovin
g an
d re
ques
ting
fund
ing
trans
fers
from
the
Fede
ral R
eser
ve
Th
ere
were
limite
d sp
ecific
writ
ten
polic
ies
and
proc
edur
es re
late
d to
the
proc
ess
for i
nitia
ting,
revie
wing
, and
app
rovin
g fu
ndin
g re
ques
ts
High
Co
ntin
ue to
bui
ld o
ut w
ritte
n po
licie
s an
d pr
oced
ures
for t
he
critic
al a
spec
ts o
f fun
ding
requ
est a
nd tr
ansf
er p
roce
ss.
Budg
et C
ontro
l/ Ex
ecut
ion
and
Re
porti
ng
Fu
nds
are
man
aged
with
a b
i-wee
kly b
udge
t to
actu
al re
port
from
BP
D –
Adm
inist
rativ
e Re
sour
ce C
ente
r’s fin
ancia
l man
agem
ent
syst
em
Th
e bu
dget
is lo
aded
at a
bur
eau-
wide
leve
l, mak
ing
indi
vidua
l bu
sines
s un
it acc
ount
abilit
y m
ore
diffic
ult t
o tra
ck
An
ICFR
con
tract
or is
wor
king
with
CFP
B on
initia
l risk
ass
essm
ent
and
will e
vent
ually
per
form
test
s of
ope
ratin
g ef
fect
ivene
ss o
f key
co
ntro
ls
Th
ere
were
limite
d sp
ecific
writ
ten
polic
ies
and
proc
edur
es re
late
d to
the
proc
ess
for b
udge
t aut
horiz
atio
ns a
nd a
lloca
tions
and
for
initia
ting,
revie
wing
, and
app
rovin
g ex
pend
iture
requ
ests
High
CFPB
sho
uld
cont
inue
to m
ake
prog
ress
with
its w
ork
unde
rway
to
mor
e-fu
lly d
ocum
ent p
olici
es re
late
d to
bud
get f
orm
ulat
ion
and
exec
utio
n / c
omm
itmen
t con
trol.
Supp
lem
enta
l doc
umen
tatio
n sh
ould
be
deve
lope
d de
finin
g de
taile
d fu
ndin
g an
d bu
dget
ary
proc
edur
es, r
oles
and
re
spon
sibilit
ies,
and
per
form
ance
man
agem
ent a
nd m
onito
ring
prac
tices
.
We
supp
ort t
he b
urea
u’s
plan
to b
egin
load
ing
the
budg
et a
t a
divis
iona
l leve
l in F
Y 20
12.
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
123
Table 31 presents list of considerations for CFPB compiled from our outreach with the Department of the Treasury – BPD – Administrative Resource Center as well as two comparable U.S. federal agencies with unique funding mechanisms and missions similar to that of CFPB (i.e., FDIC and OCC). These collective experiences, ideas, and recommendations are provided such that CFPB can further define and improve its budgeting process while it evolves as a bureau.
Table 31: Best Practices Considerations from Agency Outreach
Best Practices Considerations for CFPB as Organizational and Budget Processes Evolve
Multi-Year Budgeting:
In additional to the two-year budget formulation process (i.e., one year forward for the Operating Plan and two years forward for the President’s Budget), at least one agency recommended that CFPB implement a multiple-year investment planning process especially for significant capital expenditures that might have longer funding requirements.
Budget Formulation:
Two reference agencies strongly suggested that CFPB consider using a predominantly top-down approach to budget formulation. In the case of one agency which has used this method for at least 5 years and without any bottom-up budget calls, they discouraged the use of any extensive bottom-up approach.
While appreciative of the start-up operations for CFPB, a reference agency strongly encouraged the use of extensive budget expenditure research and comprehensive analysis prior to laying down an initial baseline budget each year. This agency found historical expenditures to be a strong predictor of future budgetary needs.
A reference agency recommended leveraging a centralized budget staffing model with a core team of budget analysts at headquarters along with at least one resource overseeing the agency’s performance management and review plans (e.g., GPRA-MA or a comparable program). Thereafter, each major departmental or division would have embedded budget analyst(s) – depending on size – which closely coordinated their work with that of the headquarters staff.
A reference agency recommended the use of budget “self-discipline” suggesting flattening or bringing the budget down in times of decreasing enforcement or oversight actions. This agency added this was especially relevant in their case where their funding was principally from risk-based insurance premiums levied on related entities.
Budget Execution and Performance Management
A reference agency recommended as a best practice extensive quarterly expenditure and performance measurement analysis reviewed against goals. This agency also performs a mid-year true-up of the budget, where necessary. Close monitoring of the budget execution results are made to make sure there is no “gaming” taking place.
This same agency has a relatively extensive performance-based pay program linked to “corporate” goals of the agency.
A reference agency suggested that, where possible, the formulated budget and agency performance measures (e.g., GPRA-MA or a comparable program) be approved at the same time to drive tighter alignment and integration.
Independent Performance Audit of CFPB Operations and Budget October 15, 2011
124
Best Practices Considerations for CFPB as Organizational and Budget Processes Evolve
Budgeting and Performance Management Technology
A reference agency currently using spreadsheets for budget formulation recommended strong version control and historical archiving practices to avoid issues cropping up during the iterative cycles of formulation. Use of structured file naming conventions was a critical solution for this agency in lieu of a more sophisticated budget formulation solution.
This same agency commented that access to historic data was extremely helpful for accurate and effective budget formulation (in their case, they had access to an extensive financial and operational data warehouse for budget research and analysis). This agency found historical expenditures to be a strong predictor of future budgetary needs.
Another reference agency found the implementation of a budget formulation and execution software solution helpful to manage workflow needs and address version control requirements.
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Appendix A: List of CFPB Officials who Provided Input
Operational Area CFPB Officials who Provided Input to this Audit
Human Capital and Organizational Development
Eben Darling, Team Lead, CHCO Operations Marilyn Dickman, Duputy Chief Human Capital Officer Dennis Slagter, Chief Human Capital Officer (CHCO) Mary Tamberrino, Team Lead, Workforce Planning & Strategic Initiatives, CHCO
Consumer Response
Sartaj Alag – Assistant Director, Consumer Response Darian Dorsey – Data/Analysis Lead Andrew Fay – Investigations Manager Cordelia Holmes – Manager, Intake Chris Johnson – Acting Section Chief, QA/Intake Steve Kirchgraber – Investigations Manager Christi Monk – Quality Analyst Scott Pluta – Attorney Advisor, Consumer Response Deb Reilly – Former Implementation Team Lead, Consumer Response Cathaleen Skinner – Attorney Advisor Julie Vanderslice – Investigations Manager LaShaun Warren – Product Development Manager
Information Technology
David Forrest – Chief Technology Officer Rachael Goldfarb – Acting Deputy CTO, Technology & Innovation Neeraj Gupta – Project Manager, Technology & Innovation Team Ori Lev – Deputy Assistant Director for Enforcement Litigation Joanna Pearl – Enforcement Attorney Nellisha Ramdass – Project Manager, Technology & Innovation Team Chris Willey – Chief Information Security Officer Mike Witt – Chief Information Security Officer
Communications and Transparency
Flavio Cumpiano – Congressional Liaison David DuBois – Deputy Director, Office of Servicemember Affairs Leandra English – Senior Advisor, External Affairs David Forrest – Chief Technology Officer Gail Hillebrand – Associate Director, Consumer Education and Engagement Jen Howard – Acting Assistant Director, Media Relations Peter Jackson – Acting Assistant Director, Office of Engagement Zixta Martinez – Assistant Director, Community Affairs Martin Michalosky – FOIA Manager Jeff Reilly – Executive Secretary Chris Willey – Chief Information Officer Mike Witt – Chief Information Security Officer
Budget
Ed Bustillo – Budget Analyst Judith Ochs – Program Analyst Victor Prince – Deputy Chief Operating Officer Jack Roziner – Audit and Internal Controls Manager Freddy Velez – Acting Chief Financial Officer Brian Winseck – Budget Analyst
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Appendix B: List of Acronyms
AAR After Action Reviews
ACSI American Customer Satisfaction Index
AFR Americans for Financial Reform
ASR ASR Analytics, LLC
ATO Authority to Operate
B2B Business to Business
B2C Business to Consumer
BFEM Budget Formulation & Execution Manager
BPD Bureau of Public Debt
CAB Consumer Advisory Board
CFO Chief Financial Officer
CFPB Consumer Financial Protection Bureau
CHCO Chief Human Capital Officer
CIO Chief Information Officer
CIPSEA Confidential Information Protection and Statistical Efficiency Act
CIS Consumer Information System
CISO Chief Information Security Officer
COOP Continuity of Operations Plan
CR Consumer Response
CTO Chief Technology Officer
DOJ Department of Justice
ECQ Executive Core Qualification
EVM Earned Value Management
FASA Federal Acquisition Streamlining Act
FDIC Federal Deposit Insurance Corporation
FFATA Federal Funding and Accountability Transparency Act
FHFA Federal Housing Finance Agency
FIRREA Financial Institutions Reform Recovery and Enforcement Act
FISMA Federal Information Security Management Act
FITD Federal Information Technology Dashboard
FOIA Freedom of Information Act
GAGAS Generally Accepted Government Auditing Standards
GAO Government Accountability Office
GPRA Government Performance and Results Act
GPRA-MA Government Performance and Results Act Modernization Act
HCAAF Human Capital Assessment and Accountability Framework
HCMR Human Capital Management Report
HCPP Human Capital Program Plan
HR Human Resources
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ICBA Independent Community Bankers of America
ICFR Internal Control over Financial Reporting
IRB Investment Review Board
IT Information Technology
ITIM Information Technology Investment Management
IVR Interactive Voice Response
LAN Local Area Network
MOU Memorandum of Understanding
NFC National Finance Center
OCC Office of the Comptroller of the Currency
OFE Office of Financial Education
OIP Office of Information Policy
OPM Office of Personnel Management
OSA Office of Servicemember Affairs
PII Personally Identifiable Information
PIR Post Implementation Review
PMO Program Management Office
POV Point of View
PRA Paperwork Reduction Act
SHCP Strategic Human Capital Plan
SORN System of Record Notices
WAN Wide Area Network
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Appendix C: Audit Team
Dr. Peter Arena served as co-lead evaluator for Information Technology. Dr. Arena is a Founding Principal of ASR Analytics and has more than 15 years of experience in information technology, program evaluation, data management, and applied econometric modeling. He has held leadership positions with major global consultancies, and is a published expert in the fields of business intelligence and application development. For the past 10 years, Dr. Arena has led a broad range of analytic studies, involving large-scale data collection, database design and integration, application development, and relational database management. He has also led large-scale evaluations of operational performance for the Department of Commerce, the Department of the Interior, and the Department of Defense.
Edward Hau served as co-lead evaluator for Budget Formulation and Execution. Mr. Hau, a Director with RSM McGladrey, has more than 23 years of global consulting experience, focused on regulatory consulting, operations, and technology risk management. He has led or managed over 40 SOX / OMB A-123 and internal audit engagements in both the commercial and public sector with a focus on IT audit readiness, risk assessment, and controls evaluation. Mr. Hau also has deep expertise in the delivery of OMB A-123, Appendix A, business process reengineering, and Federal financial management transformation services, and has helped clients yield clean opinions related to Internal Controls over Financial Reporting (ICFR).
Michele Lebar served as lead evaluator for Human Capital and Organizational Development. Ms. Lebar has more than 20 years of experience in organizational development and change management consulting, including leadership/talent development/coaching, succession planning, and performance management. Ms. Lebar’s experience includes work with a variety of private sector industries, as well as extensive work with the Federal Government. Her recent work has included the design of a succession management training program for the Internal Revenue Service and the design of an organization development program for the Washington Metro Area Transit Authority. She holds a M.S. in Organizational Development from Johns Hopkins University.
Edward Merrill served as co-lead evaluator for Information Technology. Mr. Merrill, a Director with ASR Analytics, has more than 30 years of technical and program management experience in the federal government and commercial markets, specializing in IT strategic planning, ERP enhancement/integration, and infrastructure initiatives. He has managed business units and contracts in CMMI Level 3 and ISO 9000 environments, and has successfully managed multiple projects for software engineering, portal development, content management, ERP enhancement, and information assurance. Mr. Merrill has developed IT portfolio management and Software Development Life Cycle (SDLC) methodologies for large-scale program management offices, and has performed Independent Project Oversight (IPO) and IV&V engagements for both commercial and government organizations.
Sarah Sheehan served as co-lead evaluator for Budget Formulation and Execution. Ms. Sheehan, a Manager with RSM McGladrey, has more than 12 years of experience in public
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sector financial consulting. Her recent work has involved leading “transition team” projects for the incoming President of Cook County, IL and the incoming Mayor of Chicago – with responsibility for streamlining budgeting and funding processes. Prior to joining McGladrey, Sarah served in the Governor’s office of the State of Illinois, where she managed the State’s American Recovery and Reinvestment Act program, with responsibility for $14 billion in ARRA money. Previously she worked in Deloitte Consulting’s public sector practice, where she specialized in budgeting, financial management and process redesign. Sarah has also worked at the City of Chicago’s Department of Public Health as the Assistant Commissioner of Finance, managing the department’s budget and more closely aligning its financial and contractual processes.
Michael Stavrianos served as Project Manager for this performance audit. Mr. Stavrianos, a Founding Principal of ASR Analytics, has nearly 20 years of professional experience in the fields of project management, program evaluation, and requirements management. Over the past 12 years, he has managed a broad range of analytic consulting engagements for the Internal Revenue Service (IRS), including 4 years leading the development of business rules and requirements for various Business Systems Modernization programs. He has also led recent, large scale evaluations of operational performance for both the IRS and the Department of Defense. In addition, he has designed and administered customer surveys for numerous Federal agencies, and he has served as a subject matter expert on several analytical projects for the IRS. He has been credentialed as a Project Management Professional (PMP) by the Project Management Institute.
Melissa Toledo served as lead evaluator for Consumer Response. Ms. Toledo is a Senior Director of Research and Strategy with RSM McGladrey, with more than 14 years of professional experience including strategic planning, business analysis, program management, systems implementations, and market research. Her expertise in business planning and strategy implementation has achieved profound impacts on corporate efficiency and productivity. Ms. Toledo built and manages a department that uses market intelligence to better serve clients, improve competitive differentiation and maximize growth. She was instrumental in the development of the firm’s first client loyalty measurement system and has also established several firm-wide performance initiatives that have resulted in significant improvements in client-experience ratings.
Tucker Warren served as lead evaluator for Communications and Transparency. Mr. Warren, a Managing Director with Hamilton Place Strategies, is a strategic communications professional with more than a decade of experience designing, implementing and managing small and large-scale campaigns for both the public and private sector. Most recently, he directed communications for the Financial Crisis Inquiry Commission – established by Congress to examine the causes of the financial and economic crisis. He served as the day-to-day spokesperson, developed the overall communications strategy, prepared commissioners for press conferences and hearings and handled the release of the Commission’s final report. Prior to this, Mr. Warren provided crisis communications counsel, conducted audits of internal and external communications programs, and evaluated long-term communications strategies for Edelman public relations. His clients included a top-tier multinational banking corporation, a multi-billion dollar government agency, and a prestigious Ivy League university.
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