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CFPB Report: 2013-AE-C-011 August 26, 2013

Opportunities Exist to Enhance the CFPB's Policies, Procedures, and Monitoring Activities for Conferences

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Appendix C: Management's Response

1700 G Street NW, Washington DC 20552

August 20, 2013

Mr. Mark Bialek
Inspector General
Board of Governors of the Federal Reserve System and
Consumer Financial Protection Bureau
20th and C Streets, NW
Washington, DC 20551

Dear Mr. Bialek:

Thank you for the opportunity to review and comment on the Office of the Inspector General's draft report "Opportunities Exist to Enhance the CFPB's Policies, Procedures, and Monitoring Activities for Conferences." We have reviewed the report and concur with the draft recommendations.

We appreciate your acknowledgement of the Bureau's efforts to strengthen its monitoring activities, policies and procedures. As discussed in the report under the heading "Commendable Actions," prior to your review, the Bureau initiated an internal review of its conference policies and practices to assess the adequacy of Bureau policies and identify opportunities for improvement. We appreciate your recognition that the Bureau has already taken action to enhance the Bureau's practices and procedures and, informed by our internal assessment as well as your review, we will continue to implement enhancements going forward.

The information in this report addresses testing that was conducted through September 30, 2012. We are pleased that your review identified no material discrepancies in the sampled conference expenses. The Office of the Chief Financial Officer and the Office of Human Capital have already begun to take action on your draft recommendations. Our comments below provide additional perspective on each of the recommendations and the Bureau's planned and completed actions.

Thank you again for the opportunity to comment on this report.



Sartaj Alag
Chief Operating Officer

Recommendation 1: We recommend that the CFO update policies and procedures to accurately reflect the current processes for conference coordination and approval. Updates should 

  • define the title, level or position of individuals authorized to coordinate and approve conferences.
  • clarify the procedures for all conference acquisition approaches, including BDPARC.

Management concurs with this recommendation and notes that, as discussed in the OIG's report, the existing conferences policy does identify the roles and responsibilities for conference coordination and approval. The Bureau is currently in the process of enhancing the conferences policy to provide additional detail regarding employees authorized to coordinate and approve conferences, meetings, and other events. The updated policy will also identify all conference acquisition approaches utilized by the Bureau and provide additional detail regarding the criteria for each approach. The Bureau will continue to revisit and update this policy periodically to reflect evolving Bureau practices in order to ensure that conference costs and activities are appropriately and efficiently utilized.

Recommendation 2: Periodically review and update existing policies and procedures related to conferences to ensure that they are consistent with each other and with current practices. 

Management concurs with this recommendation. Since the Bureau's launch on July 21, 2011, it has made considerable progress in developing the policies and procedures necessary to carry out its mission. As the Bureau's internal practices have evolved in scope and complexity, it periodically revisits these policies and procedures in an effort to ensure that they reflect the most up-to-date and best practices and are consistent with other Bureau policies and procedures. In addition to updating the existing conferences policy, the Bureau is simultaneously reviewing other policies and procedures related to conferences to ensure a consistent and coordinated framework. These periodic reviews will be a part of continuing efforts to update and improve the Bureau's processes.

Recommendation 3: We recommend that the OHC amend the Non-Academic External Training and Education Policy to require that the OHC conduct monthly reviews to ensure the receipt of training certifications and affidavits. 

Management concurs with this recommendation. Since the conclusion of the OIG's test work, the Bureau has reviewed the referenced policy, procedures, and related documentation. The Bureau has already taken actions to clarify and enhance the policy language, and has created an External Training Standard Operating Procedure (SOP) outlining the roles and responsibilities of each Bureau employee in the process. Further, since the end of the test period, September, 2012, OHC has automated the SF-182 External Education Request form, incorporating it into the Learning Management System (LMS) which enhances the workflows, records approval steps, and provides the needed documentation to support the Policy. OHC has benchmarked other agencies in accordance with like policies and procedures, and finds them in alignment with our enhanced approach. OHC has also created revisions to the External Training Policy to clarify language and separate tasking steps into the SOP for cleaner language and processing. Lastly, as part of the SOP, OHC has clarified process and language to ensure the proper receipt of training certifications and affidavits, and has created an audit process to outline a monthly review against these procedures and documentation.

Recommendation 4: Follow up with conference attendees and supervisors to obtain outstanding documentation. 

Management concurs with this recommendation. By automating the SF-182 External Training Request Form, and incorporated it into the Learning Management System (LMS), OHC bolstered the documentation of requesting employees, supervisors, and OHC as part of the approval and record keeping for conference requests. The last step in the automated SF- 182 workflow, includes a verification process completed by both the employee and the supervisor, validating that that the employee did, in fact, attend the conference. This approach is utilized by other federal agencies that the Bureau has benchmarked following the OIG Audit findings. Further, OHC has outlined this process in a new standard operating procedure (SOP) for external training, which outlines process steps to ensure the proper receipt of training certifications and affidavits. Also as part of the external training SOP, OHC has created an audit process to for monthly review against these procedures and documentation of employee conference attendance. OHC anticipates full implementation of the updated audit process by October, 2013.