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CFPB Report: 2017-SR-C-004 March 15, 2017

The CFPB Can Strengthen Its Controls for Identifying and Avoiding Conflicts of Interest Related to Vendor Activities

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The CFPB's Office of Fair Lending and Equal Opportunity works to ensure that consumers have fair, equitable, and nondiscriminatory access to credit for mortgages and other loans. We assessed whether the agency effectively identifies and avoids the risk of potential conflicts of interest for vendors supporting this work.

Though we did not find actual conflicts of interest, one vendor's relationships with supervised entities heightened the risk of possible conflicts of interest and increased the need for more timely vendor disclosures and communications. We also found that performing more work internally rather than choosing to outsource that work may effectively mitigate such risks.

Our report contains recommendations to reduce the agency's exposure to operational and reputational risk.