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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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Finding 2: RMR’s Document Management System Could Be Improved

Although RMR uses a centralized repository for rulemaking supporting documentation, we found that the division's approach for storing this documentation is inconsistent and informal. The CFPB has an agency-wide records management policy that obligates the agency to maintain records for easy retrieval, and RMR's interim guidance generally discusses document management. However, the interim guidance does not prescribe a formal structure to catalog RMR's records. A standard approach to managing documents could simplify the process for responding to requests.

Proprietary Shared Drive Is Used Informally to Store Supporting Documents

We found that RMR maintains the documentation associated with its rulemakings in a centralized repository on a proprietary shared drive. However, we were informed through interviews that each rulemaking team created an electronic folder for the rulemakings in process and used a file classification system of its choice.

The CFPB's Policy for Records Management interprets sections of the Federal Records Act, including National Archives and Records Administration regulations that affect the records management programs of federal agencies. The policy states that the agency's employees are obligated to maintain records so that the information is easily retrievable. Further, RMR's Interim Guidance on Regulatory Analysis for Substantive Rulemakings under the Dodd-Frank Act notes that rulemaking staff will preserve key data, spreadsheets, and computer programs relied on to perform calculations in a centralized repository.

The lack of a standard approach to storing rulemaking documentation may have contributed to difficulties retrieving supporting documentation for our evaluation. We understand that gathering rulemaking supporting documentation in general can require considerable effort, and for the Loan Originator Compensation Requirements Under the Truth In Lending Act rulemaking in particular, gathering documentation would require a substantial amount of effort because of the rulemaking's complexity. We believe that these challenges indicate that RMR could benefit from a standard approach to managing electronic documents; such a structure would foster consistency and facilitate the retrieval of documentation.


We recommend that the Associate Director of RMR

  1. Establish a standard approach to managing electronic documents that facilitates retrieval of rulemaking supporting documentation.
  2. Work with the Chief Administrative Officer and Chief Information Officer to ensure that the standard approach complies with the CFPB's Policy for Records Management, in addition to other applicable provisions, such as the Federal Records Act, including National Archives and Records Administration regulations, specifically 36 C.F.R. part 1236, Electronic Records Management.

Management's Response

The Associate Director of RMR concurred with this recommendation. In his response, the Associate Director agreed that the adoption of a formal file structure by RMR would be an effective tool to facilitate the retrieval of information and would help document and standardize current practices.

The Associate Director stated that the establishment of a recommended approach to file and document management will be incorporated into RMR's design and operations plan for fiscal year 2015. RMR will consult with the appropriate CFPB officers and offices to ensure that the approach complies with applicable CFPB policies, federal records laws, and regulations. In addition, the Associate Director stated that the CFPB is planning to implement an enterprise- wide electronic document management system, and RMR will be participating in the workgroup assessing potential options. Participation in the workgroup will be part of RMR's efforts to promote a consistent approach to managing electronic documents and to facilitate the retrieval of information.

OIG Comment

We believe that the actions described by the Associate Director of RMR are responsive to our recommendation. We intend to follow up on RMR's actions to ensure that this recommendation is fully addressed.