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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 CFPB’s strategic planning, performance planning, and QPR processes through the fourth quarter of FY 2013.17
To assess the CFPB’s 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:
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 SEFL’s and RMR’s 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 CFPB’s compliance with GRPA, we reviewed all GPRA provisions, reviewed CFPB Legal Division memorandums to determine the applicability of GPRA requirements, and analyzed the CFPB’s 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 OIG’s memorandum report, Observations and Matters for Consideration Regarding the CFPB’s 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.