The CFPB Can Further Enhance Internal Controls for Certain Hiring Processes

Appendix C: Management’s Response

CONSUMER FINANCIAL PROTECTION BUREAU
1700 G Street, N.W.
Washington, DC 20552

August 14, 2015

Ms. Melissa M. Heist
Associate Inspector General for Audits and Evaluations, Office of Inspector General
Board of Governors of the Federal Reserve System and Consumer Financial Protection Bureau
20th and C Streets, NW
Washington, DC 20551

RE: Evaluation of the CFPB's Employee Recruitment and Selection Processes

Dear Ms. Heist,

Thank you for the opportunity to review and comment on the Office of Inspector General's draft report titled, "The CFPB Can Further Enhance Internal Controls for Certain Hiring Processes". We have reviewed the report and appreciate the two recommendations provided.

1. Enhance the Office of Human Capital's monitoring efforts by including additional steps designed to assess whether internal controls related to the CFPB's recruitment and selection processes are designed and operating effectively.

Management concurs with this recommendation. In an effort to enhance the monitoring process, the Office of Human Capital (OHC) will formally document all activities that are currently being performed around the recruitment and selection process, including new monitoring activities that will be developed in response to the OIG's review. OHC will also establish a schedule on which to formally review' and assess the results of these monitoring activities. We will complete this by March 31, 2016. 

2. Fully implement the staffing efficiency performance metric, finalize the internal policy that defines target completion dates for each hiring step and finalize a process to track actual performance against the target completion dates.

Management concurs with this recommendation. Since the conclusion of the OIG's evaluation, OHC has implemented a new automated tool to track completion dates for each step in the hiring process and begun populating the tool with data from CFPB hiring actions. That data will be used to determine the Bureau's actual "baseline" performance, and then to set target completion dates for each step in the hiring process. Once target completion dates are set, we will finalize an internal policy to document the metrics that we will track and report. CFPB is on track to implement the tracking and reporting process by the end of the current calendar year.

We appreciate the OIG's thorough review of the OHC's employee recruitment and selection processes. Your recommendations will help CFPB to further enhance its hiring process and associated internal control functions.

Sincerely,
Jeffrey Sumberg  
/signed/
Chief Human Capital Officer