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We conducted this audit of the CFPB's CPF to determine whether the CFPB has developed controls to implement the statutory provisions concerning the CPF. When we initiated this project in June 2013, the CFPB had published the Consumer Financial Civil Penalty Fund Final Rule (CPF rule),2 was receiving comments, and had developed its internal CPF procedures. Prior to the start of our audit, the CFPB approved its first allocation of payments to victims and consumer education and financial literacy programs. As of November 30, 2013, the CFPB had approved its second allocation of payments to victims but had not yet implemented any consumer education and financial literacy programs.
We reviewed the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) section related to the CPF; relevant CFPB policies and procedures; decision memorandums; draft solicitations; the CPF rule and comments; and industry best practices, such as the U.S. Government Accountability Office's (GAO) Standards for Internal Control in the Federal Government.3 We also interviewed CFPB officials involved with the CPF, including the Fund Administrator, officials in the Office of the Chief Financial Officer (OCFO), and officials on the Governance and Compliance Team and the Internal Controls Team, all of whom are located in the CFPB's Washington, DC, offices. We could not conduct testing of disbursements from the CPF because the CFPB did not start disbursing CPF funds until the middle of November 2013, at the end of our fieldwork.
We performed this audit from June 2013 to November 2013. We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our observations and conclusions based on our audit objective. We believe that the evidence obtained provides a reasonable basis for our observations and conclusions based on our audit objective.