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June 12, 2014
Mr. Mark Bialek
Board of Governors of the Federal Reserve System and
Consumer Financial Protection Bureau
20th and Constitution Avenue, NW
Washington, DC 20551
Dear Mr. Bialek,
Thank you for the opportunity to review and comment on the Office of the Inspector Generalís draft report The CFPB Has Established Effective GPRA Processes, but Opportunities Exist for Further Enhancement. The CFPBís management appreciates your acknowledgement that over a short period of time the CFPB has developed effective and robust strategic and performance planning processes and that the Bureauís top leaders have demonstrated commitment to these processes. As noted in your report, the Government Accountability Office has found that support for strategic and performance planning at the highest level of an organization is the single most important factor in the success of any performance improvement initiative. The Bureauís leaders have taken this responsibility seriously, and the successes noted in your report are the result.
We also appreciate your recognition of the Bureauís focus on development of division-level strategic plans and a quarterly performance review process as a commendable action. Involving division-level management in strategic and performance planning has created an environment in which leaders throughout the Bureau hold themselves accountable for successful performance towards strategic goals.
The CFPB maintains a strong commitment to ensuring transparency of the agencyís goals, expected outcomes, and performance measures, and we continue to invest in efforts that promote greater effectiveness and accountability across the agency. Our Managementís Response provides the CFPBís perspective on recommendations made in the OIGís report, highlights enhancements made since your review, and outlines our proposed approach for building on successes achieved to date.
Chief of Staff
Formal program evaluations recommendation: Identify areas in which formal program evaluations as described by the U.S. Government Accountability Office, could assist the CFPB in meeting its goals.
The OIGís fieldwork covered the CFPB planning and performance review processes for FY2012 and FY2013, when the CFPB focused on standing up its programs and reporting systems. As noted in the course of discussions with the OIG team, throughout FY2012 and FY2013, the CFPB relied on the agencyís robust quarterly review process (QPR) and regular program reviews between the Director and the division officials to develop baseline assessments of the overall effectiveness of the agencyís programs. Since the conclusion of the OIGís fieldwork, the CFPB has engaged third parties to conduct formal effectiveness evaluations in some of the key programmatic areas, such as the supervision examinations reporting process and strategic communications. The CFPB will continue to utilize its QPR process and program reviews with the Director to identify holistically and systematically additional areas for formal program evaluations, as recommended by the OIG and the U.S. Government Accountability Office, and will engage internal and/or third party resources to conduct program evaluations with a view to further improving program designs and sharing favorable practices to address this recommendation. As described in managementís response to the OIGís second recommendation, the CFPB will develop a multi-year schedule for these additional program evaluations.
Schedule for program evaluations recommendation: Establish a schedule for program evaluations and incorporate the schedule into future strategic plans to fully satisfy the strategic planning requirements of the Government Performance and Results Act of 1993, as amended by the GPRA Modernization Act of 2010.
Based on decisions identified in the course of the quarterly performance reviews (QPRs) and regular program reviews between the Director and the division officials, the CFPB will develop and update a multi-year schedule for program evaluations. The CFPB will incorporate the schedule into its future strategic plans to fully satisfy requirements of the Government Performance and Results Act of 1993, as amended by the GPRA Modernization Act of 2010 to address this recommendation.
Annual performance plan enhancement recommendations: Build on the CFPBís efforts to comply with the Government Performance and Results Act of 1993, as amended by the GPRA Modernization Act of 2010, by satisfying all applicable requirements in its annual performance plan. Specifically, future performance plans should:
The CFPB is committed to advancing the overarching intent of GPRA and promoting greater efficiency, effectiveness, and accountability through the CFPBís planning processes. The CFPB has further enhanced its planning efforts following the FY2012-13 period in scope of the OIGís fieldwork and will continue to increase robustness of its annual performance planning. In particular: