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CFPB Report: 2014-MO-C-008 June 30, 2014

The CFPB Has Established Effective GPRA Processes, but Opportunities Exist for Further Enhancement

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Appendix A: Scope and Methodology

The overall objective for this audit was to assess whether the CFPB has implemented effective GPRA processes and whether the CFPB is in compliance with applicable sections of GPRA. The scope of our audit included the CFPBs strategic planning, performance planning, and QPR processes through the fourth quarter of FY 2013.17
                    
To assess the CFPBs GPRA processes, we interviewed agency representatives from the OCSO and the OCFO, as well as division representatives from the four divisions that are primarily responsible for executing strategic plan goals: Supervision, Enforcement, and Fair Lending (SEFL); Research, Markets, and Regulations (RMR); Consumer Education and Engagement; and Operations.

We reviewed CFPB documentation of its GPRA processes, including the following:

  • April 2013 Strategic Plan, Budget, and Performance Plan and Report
  • FY 2013 QPR presentations for all six divisions18
  • FY 2013 division-level strategic plans for all six divisions
  • data reliability policies and procedures
  • other strategic planning documentation

We also reviewed GAO reports to gain an understanding of GPRA implementation across the federal government and practices GAO highlighted as effective for implementing GPRA.

We conducted independent testing of five performance measures reported by SEFL and RMR for FY 2012. To accomplish this task, we reviewed publicly available information and internal information provided by the CFPB to verify the accuracy of performance information reported for FY 2012. We also relied on work conducted under two ongoing OIG projects as it related to our testing of SEFLs and RMRs performance measures.

Finally, we benchmarked with two other federal financial regulators. These regulators are similar to the CFPB in size and function and have more established GPRA processes.

To assess the CFPBs compliance with GRPA, we reviewed all GPRA provisions, reviewed CFPB Legal Division memorandums to determine the applicability of GPRA requirements, and analyzed the CFPBs April 2013 Strategic Plan, Budget, and Performance Plan and Report to determine whether all applicable GPRA requirements were met.

In addition, we conducted an analysis related to one observation noted in the OIGs memorandum report, Observations and Matters for Consideration Regarding the CFPBs Annual Budget Process.19 The observation stated that the CFPB inconsistently reported performance information in the early quarters of FY 2012. We reviewed FY 2013 performance information and verified that the information was consistently reported across all divisions and all quarters.

We conducted our fieldwork from September 2013 to April 2014. 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 findings and conclusions based on our audit objective. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objective.

  • 17. We did not assess compliance with annual performance reporting requirements, as the CFPB was not required to submit a performance report during the period of our review. However, we note that even though it was not required, the CFPB issued a performance report on its FY 2012 performance.Return to text
  • 18. The six divisions include SEFL, RMR, Consumer Education and Engagement, Operations, Legal, and External Affairs.Return to text
  • 19. Office of Inspector General, Observations and Matters for Consideration Regarding the CFPBs Annual Budget Process, OIG Report No. 2013-AE-C-018, October 22, 2013, http://oig.federalreserve.gov/reports/cfpb-executive-summary-20131022a.htm Return to text