The CFPB Can Improve Its Examination Workpaper Documentation Practices

CFPB examiners conduct examinations of certain financial institutions to assess compliance with federal consumer financial laws. Workpaper documentation evidences the results of this examination work. We assessed how the CFPB promotes effective documentation of examination workpapers.

We identified opportunities to improve workpaper practices by

• limiting examination employees' access to confidential or personally identifiable information so that employees can only access information that is relevant to their assigned duties
• ensuring that examination employees store documentation in the appropriate location
• documenting supervisory reviews and sampling methods consistently
• conducting training programs and internal quality reviews

Our report contains recommendations designed to enhance examination workpaper documentation practices. We acknowledge that the CFPB has taken a number of actions to address some of the issues discussed in this report prior to the report's issuance. We have not performed testing to determine whether these actions fully address our recommendations.