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CFPB Report: 2014-SR-C-013 September 29, 2014

The CFPB Complies With Section 1100G of the Dodd-Frank Act, but Opportunities Exist for the CFPB to Enhance Its Process

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Appendix A: Scope and Methodology

Our objective was to evaluate the CFPB's actions to comply with section 1100G of the Dodd-Frank Act. To accomplish our objective, we completed the following steps:

  • We reviewed relevant CFPB internal documents, including RMR's Interim Guidance on Regulatory Analysis for Substantive Rulemakings under the Dodd-Frank Act; Interim Guidance on the Small Business Review Panel Process under the Regulatory Flexibility Act, as amended by the Small Business Regulatory Enforcement Fairness Act and the Dodd Frank Act; and the CFPB's Policy for Records Management.
  • We considered provisions of the RFA found in 5 U.S.C. sections 603605 and 608609, as well as provisions for finishing the rulemaking process with the issuance of a small entity compliance guide.
  • We considered internal control guidance in Standards for Internal Control in the Federal Government, issued by the Comptroller General of the United States.
  • We conducted interviews with CFPB employees, including personnel in RMR and in the Office of General Counsel who were responsible for section 1100G rulemaking and implementing RMR's interim guidance.

Initially, we found 181 proposed and final rules that were published in the Federal Register during the July 21, 2010, to April 18, 2013, time period. From a population of 25 that were subject to public notice and comment required under section 1100G rulemaking, we selected 4 rules that were required to comply with the RFA small business review panels requirements and the section 1100G cost-of-credit provisions. Additionally, we judgmentally selected 2 rules that were certified that they would not have a SISNOSE. Each proposed and final rule in our sample is summarized in appendix B.

We conducted our fieldwork from February 2013 to December 2013. We performed our review in accordance with the Quality Standards for Inspection and Evaluation issued by the Council of the Inspectors General on Integrity and Efficiency.