The CFPB Can Improve the Efficiency and Effectiveness of Its Supervisory Activities

Appendix A: Scope and Methodology

Our objectives were to (1) review key program elements, including policies and procedures, examination guidance, and controls to promote consistent and timely reporting; (2) assess the approach for staffing examinations; and (3) assess the training program for examination staff. To accomplish our objectives, we reviewed regulatory guidance, policies and procedures, and data in SES. We conducted interviews with senior officials and staff in SEFL. Our evaluation covered supervisory activities that occurred from July 2011 to July 2013.

To address our first objective, we reviewed the Dodd-Frank Act title X sections related to the CFPB’s supervision functions, including simultaneous and coordinated supervisory actions with the prudential regulators, examination authorities, and reporting requirements.¹⁷ In addition, we reviewed the CFPB Supervision and Examination Manual, version 2; the CFPB Process for Reviewing Supervisory Letters, Examination Reports, and Supervisory Actions; and the Supervisory Prioritization Approach.

We analyzed examination data in SES to assess the agency’s performance against internal reporting timeliness requirements. The analysis included only those CFPB examinations resulting in a report of examination or supervisory letter with fieldwork ending after June 15, 2012 (the date the CFPB issued reporting timeliness requirements). The analysis excluded baseline reviews, which do not typically result in a report of examination or supervisory letter. We also used the SES examination data to verify the number of examinations outstanding for longer than 90 days. Our analysis of the SES data took into account system updates in SES during the review period, including changes to the fieldwork completion date definition.

To assess the CFPB’s compliance with the Dodd-Frank Act requirement to share certain draft reports with the prudential regulators, we reviewed each of the 15 issued reports of examinations that required coordination with the prudential regulators as of July 2013. In doing so, we reviewed available documentation demonstrating timely communication between the CFPB and the prudential regulators.

We reviewed examinations for consistency with the reporting templates provided in the CFPB Supervision and Examination Manual, version 2. We sampled a report of examination and supervisory letter from each of the four regions and compared them to the templates.

To address our second objective, we evaluated the CFPB’s implementation of the supervision program by reviewing regional examination schedules, staffing documentation, and other staffing materials.

To address our third objective, we assessed the interim commissioning policy, on-the-job training modules, planning materials for the final commissioning program, and the 2012 CFPB Annual Employee Survey.

We conducted our fieldwork from February 2013 through October 2013. We performed our evaluation in accordance with the Quality Standards for Inspection and Evaluation issued by the Council of the Inspectors General on Integrity and Efficiency.

• 17. Dodd-Frank Wall Street Reform and Consumer Protection Act, Pub. L. No. 111-203, §§ 1021(c), 124 Stat. 1376, 1980 (codified at 12 U.S.C. § 5511(c)); 1024(b), 124 Stat. 1987 (codified at 12 U.S.C. § 5514(b)); 1025(b),(e) 124 Stat. 1990-91 (codified at 12 U.S.C. § 5515(b),(e)); and 1026(b),(c) 124 Stat. 1993-94 (codified at 12 U.S.C. § 5516(b),(c)) (2010).  Return to text