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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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The Government Performance and Results Act of 1993, as amended by the GPRA Modernization Act of 2010 (GPRA), was enacted to promote greater effectiveness and accountability in federal programs. We conducted this audit to assess (1) the effectiveness of the Consumer Financial Protection Bureau's (CFPB) processes that address GPRA and (2) whether the CFPB is complying with applicable sections of GPRA. The U.S. Government Accountability Office (GAO) has conducted GPRA-related reviews of executive agencies and found that executive agencies need to do more to fully implement GPRA requirements. As part of our audit, we considered GAO's findings as they relate to the CFPB's GPRA implementation. Details on our scope and methodology are in appendix A.


Federal Requirements and Guidelines

The purpose of GPRA is to hold agencies accountable for achieving program results, to improve federal program effectiveness through the setting of goals for program performance and measuring results, and to raise public confidence in the federal government. GPRA requires that most executive agencies produce strategic plans every four years and issue agency performance plans annually.1 GPRA specifies how these plans should be drafted and has requirements that describe elements that must be included in each plan. In 2010, GPRA was updated to apply lessons learned from nearly two decades of implementation. GPRA updates included requirements that agencies establish specific management and performance-focused leadership positions.

Two congressional committee reports—U.S. Senate Committee on Governmental Affairs, Government Performance and Results Act of 1993 (to accompany S. 20)2 and U.S. Senate Committee on Homeland Security and Governmental Affairs, GPRA Modernization Act of 2010, 2010 (to H.R. 2142)3 provide supplemental guidance on GPRA. In these reports, Congress expanded on specific components of the law, such as the requirement to report on program evaluations in strategic plans. One committee report noted that since its enactment, GPRA had helped improve the efficiency and effectiveness of federal programs by requiring that agencies establish a system to set goals for program performance and to measure results.

GAO has a long-standing interest in improving government management through the use of strategic planning and performance measurement. GAO has conducted in excess of 90 GPRA-related reviews across the federal government. As a result of these reviews, GAO has identified practices for effectively implementing GPRA, such as (1) ensuring that performance information is used in decisionmaking, (2) obtaining leadership's commitment and accountability for achieving results, and (3) promoting successful quarterly performance reviews (QPRs).

The CFPB's Implementation of GPRA

Title X of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act)4 established the CFPB in 2010 as an as an executive agency and as an independent bureau within, yet autonomous from, the Federal Reserve System.5 Additionally, provisions of the Dodd-Frank Act exempt the CFPB from the jurisdiction of the Office of Management and Budget (OMB).6, 7 Therefore, the CFPB determined that it is generally subject to the requirements of GPRA, except for those provisions of GPRA that require agencies to follow guidance issued by OMB or to submit to OMB's jurisdiction or oversight.8

The CFPB's Office of the Chief Strategy Officer (OCSO) coordinates the agency's GPRA-related activities through the following processes:

  • Strategic planning. The CFPB develops a four-year strategic plan that articulates the fundamental mission of the agency and lays out the agency's long-term goals for implementing that mission. GPRA requires that agency-level strategic plans be developed and published at least once every four years.
  • Performance planning. The CFPB develops an annual performance plan that contains the agency's annual performance goals and associated measures to gauge its progress toward achieving its broader strategic goals. In support of performance planning, the CFPB implemented a process to ensure the accuracy and reliability of its performance information. GPRA requires that agency-level performance plans be developed and published annually.
  • Division-level strategic and performance planning. Each division, under the leadership of its Division Associate Director, develops annual division-level strategic plans that include division-level performance goals and measures. The divisions' planning activities align with the agency-level strategic and performance plans. Division-level strategic and performance planning is not a requirement of GPRA, but the CFPB voluntarily implemented these processes.
  • Quarterly Performance Review (QPR). Each division tracks its progress toward achieving division-led strategic and performance goals on a quarterly basis and reports this progress to CFPB leadership. This process also includes follow-up on issues identified during the previous QPR. Although conducting QPRs is a GPRA requirement, it is not applicable to the CFPB due to provisions related to OMB oversight.

The OCSO led all six divisions in implementing the CFPB's GPRA-related processes. Specifically, the OCSO provided to the divisions (1) guidance on the development of meaningful performance goals and measures, (2) a QPR template to ensure agency-wide consistency in internal performance reporting, and (3) feedback throughout the implementation of the processes.

The CFPB issued its first Strategic Plan, Budget, and Performance Plan and Report in April 2013, less than two years after it began operations.9 As such, the CFPB based the Strategic Plan, Budget, and Performance Plan and Report on four broad strategic goals associated with the agency's mission and operations. Additionally, to support each of the four broad strategic goals, the CFPB developed 27 performance goals.

The CFPB Demonstrates a Commitment to Developing Effective and Efficient GPRA Processes
According to the Chief Strategy Officer, the Director of the CFPB promotes continuous improvement to make processes more meaningful and relevant and has created a data-driven culture that promotes accountability. The Director's efforts are evident in the evolution of the CFPB's GPRA activities. Initially, the OCSO established independent strategic planning, performance planning, and QPR processes. Recognizing a gap between the long-term, high-level agency strategic plan and annual performance measures, the OCSO established a division-level strategic planning process to bridge this gap. To streamline division efforts, the OCSO modified the QPR process to incorporate agency-level and division-level GPRA activities. Through these process improvements, the CFPB effectively aligned all of its GPRA-related activities into one comprehensive process. All four of the divisions responsible for the CFPB's strategic goals have attested to the benefits of this streamlined process.

  • 1. Pub. L. No. 111-352 (2011), the definition of agency is codified in 5 U.S.C. § 306(f) and specifies that GPRA applies to executive agencies, but provides specific exceptions for some agencies. Return to text
  • 2. U.S. Senate Committee on Governmental Affairs, Government Performance and Results Act of 1993 (to accompany S. 20), S. Rep. No. 103-58 (1993) reprinted in 1993 U.S.C.C.A.N. 327. Return to text
  • 3. U.S. Senate Committee on Homeland Security and Governmental Affairs, GPRA Modernization Act of 2010, 2010 (to H.R. 2142), S. Rep. No. 111-372 (2010). Return to text
  • 4. Dodd-Frank Wall Street Reform and Consumer Protection Act, Pub. L. No. 111-203, § 1011(a), 124 Stat. 1376, 1964 (2010) (codified at 12 U.S.C. § 5491(a) (2010)). Return to text
  • 5. Dodd-Frank Wall Street Reform and Consumer Protection Act, Pub. L. No. 111-203, § 1011(a), 124 Stat. 1376, 1964 (2010) (codified at 12 U.S.C. § 5491(a) (2010)).  Executive agency is defined in 5 U.S.C. § 105. Return to text
  • 6. OMB reports directly to the President and helps a wide range of executive departments and federal agencies implement the commitments and priorities of the President. Return to text
  • 7. Pub. L. No. 111-203, § 1017(a)(4)(E). According to the law, there is no "obligation on the part of the Director of the CFPB to consult with or obtain the consent or approval of the Director of the Office of Management and Budget with respect to any report, plan, forecast, or other information . . . or any jurisdiction or oversight over the affairs or operations of the Bureau." Return to text
  • 8. Additionally, certain sections of GPRA are applicable to the 24 agencies listed in the Chief Financial Officers Act of 1990. As the CFPB is not one these 24 agencies, these sections are not applicable to the CFPB. Return to text
  • 9. This document incorporates a strategic plan for fiscal years (FY) 2013–2017 and a budget and performance plan for FY 2013. Return to text