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CFPB Report: 2014-AE-C-005 March 27, 2014

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

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Finding 6: The CFPB Has Inconsistent Scheduling Practices and Has Not Tracked Examination Staff Hours

The CFPB does not have consistent scheduling practices across the regions and has not tracked actual staff hours for examiners. We did not have criteria to assess the CFPBís performance against staffing objectives because the agency is still building its supervisory program and did not have data on the expected number of examiner hours to use as a benchmark, particularly for examinations of nonbank entities. As a result, according to senior officials, examination schedules are determined on a case-by-case basis and may be extended during the examination, potentially hindering managementís ability to hold staff accountable to timeliness benchmarks. In addition, the CFPB was not tracking actual staff hours; such information could help the agency manage staff workload and identify staffing requirements.

The CFPB Does Not Have a Consistent Approach to Scheduling and Has Not Tracked Examination Staff Hours

Our review of scheduling documentation identified inconsistencies across the regions in the level of granularity in the examination schedules and the mechanisms used to document the schedules. For example, one regionís examination schedule included detail only on the lead examiner scheduled, while the other regionsí schedules included detail on the entire examination team. In addition, two regions used SES for examination scheduling, while the other two regions used spreadsheets. We also found that the CFPB was not tracking actual examiner hours spent on examinations. Without that information, the agency is unable to use historical staffing data to manage staff workload and identify future staffing requirements.

The CFPB does not have a formalized policy for scheduling or tracking staff hours on examinations. Senior officials described a fluid and informal process for planning and staffing examinations in which field managers meet to discuss examiner availability and experience. The regional directors stated that this process is generally completed at least three months in advance of examinations. Further, senior officials noted that the progress of examinations is monitored on a case-by-case basis through regular meetings.

Because the CFPB has a decentralized structure, with its examination staff located in four regions throughout the United States, the agency should have policies and procedures that set baseline expectations. The lack of a policy for scheduling and tracking examination hours hinders the CFPBís ability to hold staff and regions accountable for the staff resources allocated and time expended on examinations. We also believe that the CFPB is not optimizing an opportunity to use data from its actual examination experience to influence its future scheduling decisions.

Recommendation

We recommend that the Associate Director for SEFL

  1. Create a policy that provides a consistent approach across regions for scheduling staff on examinations and tracking actual staff hours.

Managementís Response

Regarding recommendation 9, the Deputy Director and Associate Director for SEFL stated the following:

The CFPB will, as recommended, evaluate the current processes for coordinating examination staff scheduling across regions, identify areas of potential inconsistency regarding regional staff scheduling, and enhance and/or harmonize those processes as needed to manage staff workload and identify future staffing requirements.

Since July 2013 the CFPB has substantially enhanced its existing processes and systems regarding tracking of examination staff hours. We will continue to develop and refine an associated policy.

Managementís full response is included as appendix B.

OIG Comment

In our opinion, the actions described by the Deputy Director and Associate Director for SEFL appear to be responsive to our recommendation. We plan to follow up on the CFPBís actions to ensure that the recommendation is fully addressed.