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CFPB Report: FRB OIG 2011-03 July 15, 2011

Review of CFPB Implementation Planning Activities


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On July 15, 2011, our office and the Treasury OIG jointly issued a report on the CFPB's implementation planning activities related to standing up the agency. The review's objective was to assess the CFPB's efforts to (1) identify missioncritical activities and legislative mandates; (2) develop and execute a comprehensive implementation plan and timeline for mission-critical activities and legislative mandates; and (3) communicate its implementation plan and timeline to certain key stakeholders.

Our review found that the CFPB identified and documented implementation activities critical to standing up the agency's functions and necessary to address certain Dodd-Frank Act requirements. Furthermore, the CFPB developed and was implementing appropriate plans that supported ongoing operations as well as the July 21, 2011, transfer of employees and functions. We reported the status of the CFPB's implementation progress for certain activities as follows:

  • As of June 17, 2011, 19 of the CFPB's 35 assistant director or equivalent positions had been filled. According to the CFPB, the agency also had hired a Regional Director for its San Francisco office and was in the process of recruiting leaders for its Washington, DC; Chicago; and NewYork offices.
  • As of June 30, 2011, the CFPB offered transfers to 349 employees from other federal regulatory agencies. As of that date, 172 employees had accepted the CFPB's offers, and CFPB officials were waiting for additional responses to their offers.
  • On February 13, 2011, the CFPB developed an interim pay structure to implement a payroll system. On May 8, 2011, the agency refined its pay structure, which comprises 9 pay bands consisting of 18 pay ranges.
  • According to CFPB documents, the agency plans to continue using Treasury's Bureau of the Public Debt Administrative Resource Center to provide for its financial management. The CFPB also plans to continue relying on Treasury's infrastructure for its general support systems, such as email. Contractors provide additional information technology support.
  • According to CFPB officials, starting on July 21, 2011, CFPB expected to take website inquiries and phone calls from consumers, initiate the complaint inquiry process, and begin case management for tracking complaints. However, the agency plans to initially only process complaints related to credit cards. According to a CFPB timeline, the agency plans to process complaints concerning other consumer financial products over the course of the next year.

We also reported that the CFPB communicated its planning and implementation of standup activities to internal stakeholders and provided information to other consumer regulatory agencies regarding its transfer planning. Nevertheless, we concluded that CFPB's operational success will depend, in part, on its ability to effectively execute its plans. As part of our ongoing oversight efforts, we plan to continue to monitor the progress of CFPB's implementation activities.