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CFPB Report: 2015-SR-X-009 June 1, 2015

Coordination of Responsibilities Among the Consumer Financial Protection Bureau and the Prudential RegulatorsóLimited Scope Review

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Attachment 2


GAO is required to conduct reviews of certain Dodd-Frank Act provisions and a component of its reviews assessed coordination among the CFPB and prudential regulators. We identified several completed GAO audits that addressed interagency coordination efforts between the CFPB and prudential regulators, among other matters pertaining to the Dodd-Frank Act. Those GAO reports include:

  • DODD-FRANK ACT REGULATIONS: Implementation Could Benefit from Additional Analyses and Coordination, GAO-12-151, November 2011.
  • DODD-FRANK ACT: Agencies’ Efforts to Analyze and Coordinate Their Rules, GAO-13-101, December 2012.
  • DODD-FRANK REGULATIONS: Agencies Conducted Regulatory Analyses and Coordinated but Could Benefit from Additional Guidance on Major Rules, GAO-14-67, December 2013. 
  • CONSUMER FINANCIAL PROTECTION BUREAU: Some Privacy and Security Procedures for Data Collections Should Continue Being Enhanced, GAO-14-758, September 2014.

GAO found that the CFPB and prudential regulators coordinated in various capacities and identified a limited amount of regulatory overlap pertaining to data collections. In 2011 and 2012, GAO reported that the CFPB and prudential regulators coordinated on rulemakings when required by the Dodd-Frank Act and sometimes coordinated voluntarily on rulemakings to avoid duplication and overlap. However, GAO found that the CFPB and prudential regulators generally lacked formal policies to guide their coordination efforts. In 2013, GAO reported that the CFPB established a framework to coordinate its supervision activities with the prudential regulators and continued to coordinate on rulemakings.

In 2014, GAO reported that the CFPB and prudential regulators coordinated their data requests to regulated institutions and established formal information-sharing agreements and had begun drafting additional agreements. Further, GAO found that the CFPB and prudential regulators often collected different information from financial institutions. However, the CFPB and Board collected similar credit card data from four institutions sampled.17 Staff from the two regulators stated that each used the data for different purposes.

GAO had additional assignments that were planned or underway, to assess interagency coordination.

  • 17. GAO also found some regulatory overlap among the Board and OCC pertaining to credit card and mortgage data collections. Return to text