Consumer Financial Protection Bureau (CFPB)Consumer Financial Protection Bureau 1500 Pennsylvania...

Consumer Financial Protection Bureau (CFPB)

Financial Services Omnibus Contract #: TOFS-11-D-0001 Task Order #: CFP-11-K-00021

Independent Performance Audit of CFPB Operations and Budget

Submitted October 15, 2011 by:

ASR Analytics, LLC Federal TIN: 20-1204680

1389 Canterbury Way DUNS: 15-108-3305

Potomac, MD 20854 www.asranalytics.com

Submitted to:

Consumer Financial Protection Bureau

Ms. Antona Lilly ([email protected])

1801 L Street, NW

Washington, DC 20036

1389 CANTERBURY WAY POTOMAC, MD 20854 PHONE: 301‐738‐9502 www.asranalytics.com

October 15, 2011 Mr. Raj Date Special Advisor to the Treasury Secretary for the Consumer Financial Protection Bureau Consumer Financial Protection Bureau 1500 Pennsylvania Ave. NW Attn: 1801 L Street NW Washington, DC 20036 Dear Mr. Date:

On behalf of ASR Analytics, LLC (ASR), I am pleased to enclose the attached report, which presents the results of our independent performance audit of the Consumer Financial Protection Bureau (CFPB). This audit was commissioned by the CFPB in accordance with the Full-Year Continuing Appropriations Act, 2011 (Pub. L. 112-10) of April 15, 2011, Title V, Section 1573 (a), which amended the Dodd-Frank Wall Street Reform and Consumer Protection Act to require an annual independent audit of the operations and budget of the bureau (12 USC 5496a). ASR performed this work between August 19, 2011 and October 15, 2011.

For this performance audit, ASR reviewed the operations of five key areas, which CFPB identified as instrumental in implementing the Consumer Protection Act of 2010 and standing up the CFPB as an organization: (1) Human Capital and Organizational Development; (2) Consumer Response; (3) Information Technology; (4) Communications and Transparency; and (5) the CFPB budget. To evaluate the CFPB’s operations and performance in these five areas, we relied on a combination of physical, documentary, and testimonial evidence, most of which was provided by the CFPB. We reviewed more than 250 artifacts, including policy and planning documents, status reports, briefing memos, meeting minutes, discussion decks, statements of work, and other sources. In addition, we held over 50 meetings with CFPB personnel and other stakeholders.

A draft of this report was shared with all participating stakeholders at the CFPB for review and comment. CFPB staff provided us with oral and written comments on the draft report, including several technical clarifications and suggestions, which we incorporated where appropriate.

If you have any questions about this report, please contact me at 608-467-7291 or Michael Stavrianos at 301-758-0371. Other key contributors to this report include Peter Arena, Edward Hau, Michele Lebar, Edward Merrill, Sarah Sheehan, Melissa Toledo, and Tucker Warren.

Sincerely,

Stephen Rhody Founding Principal ASR Analytics, LLC cc: Ms. Catherine West, Chief Operating Officer, Consumer Financial Protection Bureau

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Table of Contents Section 1: Executive Summary ............................................................................................................... 1

1.1 Background ............................................................................................................................... 1

1.2 Compliance with Government Auditing Standards ................................................................ 1

1.3 Organization of this Report ...................................................................................................... 2

1.4 Findings and Recommendations .............................................................................................. 3

Section 2: Human Capital and Organizational Development .......................................................... 11

2.1 Scope of Audit ........................................................................................................................ 11

2.2 Evaluation Criteria .................................................................................................................. 12

2.3 Findings and Recommendations ............................................................................................ 14

Section 3: Consumer Response ............................................................................................................. 27

3.1 Scope of Audit ........................................................................................................................ 27



Section 4: Information Technology ...................................................................................................... 49

4.1 Scope of Audit ........................................................................................................................ 49



Section 5: Communications and Transparency ................................................................................. 65

5.1 Scope of Audit ........................................................................................................................ 65



Section 6: Budget .................................................................................................................................. 109

6.1 Scope of Audit ...................................................................................................................... 109

6.2 Evaluation Criteria ................................................................................................................ 110

6.3 Findings and Recommendations .......................................................................................... 113

Appendix A: List of CFPB Officials who Provided Input ....................................................................... 125

Appendix B: List of Acronyms ..................................................................................................................... 127

Appendix C: Audit Team ............................................................................................................................... 129

Independent Performance Audit of CFPB Operations and Budget October 15, 2011

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Section 1: Executive Summary

1.1 Background

This report presents the results of an independent performance audit of the Consumer Financial Protection Bureau (CFPB) – commissioned by the CFPB in accordance with the Full-Year Continuing Appropriations Act, 2011 (Pub. L. 112-10) of April 15, 2011, Title V, Section 1573 (a) – which amended the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) to add the following text:

(a) Annual Independent Audit.--The Bureau shall order an annual independent audit of the operations and budget of the Bureau.

(b) Annual GAO Audit.--The Comptroller General of the United States shall conduct an annual audit of the Bureau's financial statements in accordance with generally accepted government accounting standards.

In order to meet this requirement, the CFPB must order an independent performance audit for FY 2011, and complete the report by October 15, 2011. For this performance audit, the bureau identified five key areas of operations, which were instrumental in implementing the Consumer Protection Act of 2010 and standing up the CFPB as an organization: (1) Human Capital and Organizational Development; (2) Consumer Response; (3) Information Technology; (4) Communications and Transparency; and (5) the CFPB budget.

It is important to note that this is a performance audit, not a financial audit, and thus does not overlap with the Annual GAO Audit described in Sec 1573 (a). Performance audits are engagements that provide findings or conclusions based on an evaluation of sufficient, appropriate evidence against defined criteria. Their purpose is to provide objective analysis to assist management in using the information to improve program performance and operations, reduce costs, facilitate decision making, and contribute to public accountability.

1.2 Compliance with Government Auditing Standards

We conducted this performance audit in accordance with generally accepted government auditing standards (GAGAS), with one exception. Namely, while all members of the audit team maintain professional competence in their respective areas of specialization, some members have ongoing efforts to achieve minimum hours of continuing professional education that directly relates to government auditing. This exception notwithstanding, we believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Information for this performance audit was derived from physical evidence, documentary evidence, and testimonial evidence, most of which was provided by the CFPB. We reviewed more than 250 artifacts over the course of this study, including policy and planning documents, status reports, briefing memos, meeting minutes, discussion decks, statements of work, and other sources. In addition, we held over 50 meetings with CFPB personnel and other stakeholders.


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1.3 Organization of this Report

Section 1 of this report is an Executive Summary. Subsequent sections present the results of our performance audit for each of the five operational areas. Section 2 focuses on Human Capital and Organizational Development; Section 3 on Consumer Response; Section 4 on Information Technology; Section 5 on Communications and Transparency; and Section 6 on Budget. Appendix A provides a list of CFPB officials who provided input to this audit; Appendix B presents a list of acronyms used in this report; and Appendix C offers a brief overview of our audit team.

Within each section, we present information on three topics: (1) audit scope; (2) evaluation criteria; and (3) findings and recommendations. Below, we summarize the information addressed within each of these topics.

1.3.1 Scope of Audit

Due to the time constraints for this performance audit, as well as the short history of the CFPB as an organization, the scope of this performance audit is necessarily limited. The purpose of this section is to define the overall scope of the review area and to enumerate the performance elements that are within the scope of this audit. The audit scope defines the subject matter that the auditors have assessed and reported on, such as a particular business process, organizational unit, or technology system. If applicable, this section also describes any significant constraints imposed on the audit due to information limitations or other scope impairments.

1.3.2 Evaluation Criteria

The purpose of this section is to describe the criteria that are used to evaluate performance. Audit criteria represent the laws, regulations, standards, requirements, measures, and benchmarks against which performance is compared or evaluated. Our audit focused on three sets of criteria: (1) compliance with the legal requirements; (2) achievement of organizational goals; and (3) alignment with performance standards, best practices, and/or benchmarks. These criteria are consistent with GAO standards for evaluation criteria, as published in August 2011 (Government Auditing Standards, 2011 Internet Version, Section A6.02). Within each section of this report, we identify the audit objectives and evaluation criteria that are specific to each review area—and we cite specific evaluation frameworks and/or methodologies that are used to support the evaluation. In order to establish a broad basis for evaluation, we rely (where possible) on established “performance frameworks”, which define a set of commonly accepted performance standards and associated criteria or metrics. For example, in the Human Capital and Organizational Development review area, we use the Human Capital Assessment and Accountability Framework (HCAAF) to establish performance standards and evaluation criteria.

1.3.3 Findings and Recommendations

Within each section, we evaluate the CFPB’s performance with respect to three sets of criteria—legal requirements, organizational goals, and performance standards. Our findings and recommendations are presented in two ways. First, within the body of the report, we provide a bulleted list of the findings and recommendations that we view as most important. Second, in a series of detailed tables, we describe the progress that the bureau has demonstrated to date with respect to each performance


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criterion, and we offer recommendations for future action. In these tables, we further characterize the bureau’s performance using “stoplight ratings” and “priority scores”, as defined below. Stoplight Ratings

Green (G): Performance to date has met or exceeded the auditor’s expectations for a new organization in all relevant criteria. CFPB has fully achieved the performance element or has made significant progress towards achieving it.

Yellow (Y): Performance to date has met the auditor’s expectations for a new organization in some but not all relevant criteria. CFPB has made progress towards achieving the performance element, but additional attention is needed.

Red (R): Performance to date has not met the auditor’s expectations for a new organization. CFPB has not made any significant progress towards achieving the performance element.

Blank (–): No expectations exist with respect to this performance element. CFPB is not expected to have demonstrated any performance in this area at this time in its standup.

Grey (?): The audit team did not receive enough information to evaluate performance at this

time.

Priority Scores

High: This is a high priority for meeting the bureau’s goals. Action should be taken as soon as possible.

Medium: This is a medium priority for meeting the bureau’s goals. Action should be taken within the next 6 months.

Low: This is a low-level priority for meeting the bureau’s goals. Nevertheless, action plans should be developed within the next year.

1.4 Findings and Recommendations

1.4.1 Summary of Performance Ratings

Across all five review areas, the CFPB has made significant progress towards achieving legal compliance, attaining organizational goals, and meeting performance standards. Through this performance audit, we rated the bureau’s performance with respect to 102 distinct performance elements. As illustrated in the figure below, the CFPB achieved a Green stoplight rating (met or exceeded expectations in all relevant criteria) for 67 (66%) of these performance elements—and achieved a Yellow rating (met expectations in some relevant criteria) for 24 (24%) of these elements.


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None of the elements received a Red score (performance has not met expectations). Following the summary table, we highlight key findings and recommendations from each of the five review areas.

Performance Rating Human Capital

Consumer Response

Information Technology Communications Budget

All Review Areas

5 (38%) 6 (33%) 6 (60%) 47 (81%) 3 (100%) 67 (66%)

7 (54%) 8 (44%) 2 (20%) 7 (12%) 0 (0%) 24 (24%)

0 (0%) 0 (0%) 0 (0%) 0 (0%) 0 (0%) 0 (0%)

0 (0%) 3 (17%) 2 (20%) 1 (2%) 0 (0%) 6 (6%)

1 (8%) 1 (6%) 0 (0%) 3 (5%) 0 (0%) 5 (5%)

1.4.2 Key Findings and Recommendations: Human Capital and Organizational Development

CFPB fully complied with the requirement to develop a Recruitment and Retention Plan, Training and Workforce Development Plan and Workforce Flexibilities Plan. CFPB delivered these plans to Congress on July 21, 2011, as part of the report Developing our Human Capital. The document identifies achievements as well as near and longer term actions in each of the three requirement areas.

CFPB met the requirement of the Dodd-Frank Act to develop a compensation and benefits program. CFPB benchmarked the Federal Reserve Board and other Financial Institutions Reform Recovery and Enforcement Act (FIRREA) agencies to come up with a comparable and competitive compensation model to attract mission-critical and support occupations.

CFPB should staff up the bureau’s leadership positions and core functions. This goal is mostly complete. To date, 4 of the 6 Associate Directors are on board and 20 of the 36 Assistant Directors are on board. Going forward, it is important to continue the search to fill needed leadership positions in a timely manner.

CFPB has transferred employees from other federal agencies to address mission-critical staffing needs. CFPB identified the major mission-critical and supporting functional positions required, and negotiated with six federal agencies for positions to support mission-critical functions being transferred to CFPB. A memorandum of understanding (MOU) was developed that specifies the agreement with the federal agencies to transfer employees into CFPB. An ‘Expression of Interest’ was implemented with federal agencies, and interviewing and selection criteria were outlined in MOUs, resulting in 232 transferees into CFPB.

CFPB should continue to implement its recruitment strategy. CFPB has done an excellent job at filling positions to stay on target with recruiting goals and should continue aggressive recruiting efforts through FY 2012 to hire the balance of personnel to staff CFPB at


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its targeted level. It is important that the bureau follow through by implementing its recruitment strategy, vision and goals stated in the September 23, 2011 presentation CFPB Recruitment Strategy & Update. There are over 400 mission critical vacancies and a number of outreach activities that have been identified for FY 2012. Dedication, commitment, coordination and expertise will be needed at all levels to accomplish these actions.

CFPB should fully develop a Training and Workforce Development Plan. The Dodd-Frank Act specifically calls for a Training and Workforce Development plan, and this continues to be a high priority and immediate need for CFPB. In the Annual Report to Congress on July 21, 2011, Developing our Human Capital, CFPB defined an approach to training and workforce development. To support their mission, CFPB has developed and held lunch and learns, on-boarding training, and approximately three weeks of training for the core Examiner and Consumer Response workforces. An assessment of workforce skills has been executed and core competencies for executives and non-executives have been developed. CFPB has a longer term goal to develop as a learning organization. In the near term, the Training and Workforce Development Plan should ensure that CFPB has a consistent and unified approach to training and workforce development, across all units and employee populations.

1.4.3 Key Findings and Recommendations: Consumer Response

CFPB’s Consumer Response function has complied with all relevant legal requirements. CFPB should use the credit card complaint standup approach – and learnings derived from its initial implementation – as a template of sorts as Consumer Response continues to expand its scope beyond the credit complaint area into mortgages and other financial products/services.

Consumer Response is in compliance with its own internal organizational performance targets in those areas where: (1) targets have been documented; and (2) CFPB has officially begun holding itself and others to performance targets that have been set thus far. CFPB should complete the standup of key remaining operational enablers. This includes launching Consumer Response’s consumer-facing knowledge base, implementing its complex case management system, and ramping up to at least minimum analyst staffing levels required to support quality assurance reviews for CFPB investigations and to develop/execute a master performance dashboard.

CFPB should finalize all remaining targets tied to major operational metrics – and begin enforcing targets as soon as possible. Consumer Response has yet to establish and/or enforce final targets for operational metrics like maximum bank/regulator response time during CFPB investigations, or standards around frequency and scope of periodic quality assurance analysis and reporting (outside the intake/call center area). The sooner CFPB establishes targets for these critical activity areas, the sooner it can begin tracking performance associated with the full scope of its mandate, and the better prepared it will be to provide periodic reporting and analysis to other stakeholders.

CFPB should consider adding consumer resolution dispute rate to its featured short-list of major operational metrics. Including this metric (i.e., % of “resolved” complaints that


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consumers subsequently dispute) can increase leadership visibility into what affected consumers may perceive as the effectiveness of current Consumer Response processes, and help uncover themes and/or emerging issues in individual bank investigation performance.

CFPB should establish a single Consumer Response master dashboard to track and communicate actual performance against targets. This master dashboard may contain different tabs/views, covering either department-wide (standup) goals or goals specific to each financial product CFPB eventually addresses. Generally, however, the goal should be to minimize differences across dashboard views to ensure appropriate focus on the core elements of Consumer Response’s mission, and to facilitate easy comprehension and interpretation of performance data.

CFPB should implement an OMB-approved consumer satisfaction survey as a basic means to begin systematically collecting feedback directly from those who are experiencing CFPB’s operations today.

CFPB should leverage the feedback it is already collecting. As an example, the bureau should establish operational goals and processes around mining contacts that are currently stored in Consumer Response’s contact management system as “feedback.”

CFPB should draft a more formal “stakeholder feedback platform” plan. The bureau should whiteboard current feedback mechanisms by key operational areas, (e.g., intake, routing, tracking/resolution, analysis), channels (e.g., website, toll-free number), and stakeholder type (e.g., prudential regulators, covered persons, consumer advocacy groups, mass consumer audiences). In order to test the relevance and value of these feedback mechanisms, CFPB should consider who will use the feedback from each data stream, how the feedback will be used, and what the bureau [or other relevant stakeholders] will do differently as a result of this feedback.

CFPB should complete the conceptual development of a feedback platform, secure approvals as needed and begin to implement. Note that “approvals” in this case means both completing relevant compliance activity (e.g., Paperwork Reduction Act-mandated work), but also securing buy-in from other CFPB offices or other key stakeholders to utilize insight generated from the feedback that Consumer Response collects and analyzes.

CFPB should continue to enhance process transparency to consumers and other stakeholders. One way to accomplish this goal is to leverage stakeholder feedback, in order to enhance the clarity of CFPB processes and performance expectations in ways that are relevant to each major stakeholder group. For consumers, one relatively quick “win” in this area would be to build notification capability to alert complainants as investigations move through CFPB’s tiers.


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1.4.4 Key Findings and Recommendations: Information Technology

CFPB has used Information Technology (IT) to support customer service. With the development of the Consumer Information System (CIS) and the CFPB website, the IT department has created an engaging digital experience. The use of “Tell Your Story” and “Know Before You Owe” on the website offer further evidence of progress in this area. We recommend that the IT organization continue its emphasis on this goal and conduct a formal review of the usability of the website.

CFPB has aligned its information technology assets with its strategic missions, in accordance with the Clinger-Cohen Act of 1996. This alignment is managed by the Investment Review Board (IRB), and documented at a high level through the IRB dashboard. Specifically, the IRB dashboard identifies each of the Initial Systems (technology assets) being developed by CFPB, and links each asset to either: (1) a specific element of CFPB’s mission; or (2) a specific enterprise or business service.

CFPB has complied with key elements of the E-Government Act of 2002, including the Federal Information Security Management Act (FISMA) and the Confidential Information Protection and Statistical Efficiency Act (CIPSEA). Specifically, CFPB obtained authority to operate (ATO) for: (1) connectivity to the Treasury infrastructure; and (2) protection of confidential and/or personal information in CIS. We recommend that CFPB continue their approach to retaining personal information and conducting FISMA audits. CFPB has already demonstrated behaviors consistent with this, for example, by submitting System of Record Notices (SORN) that address items such as the individuals covered by the system, categories of records in the system, purpose of the system, categories of users of the system, storage, retrievability, and safeguards.

CFPB should continue to build human capital for the IT function. CFPB has made appropriate progress towards this goal. It has named a Chief Technology Officer, Chief Information Officer and Chief Information Security Officer – and it has established a productive IT organization through an integrated team of government and contractor personnel. We recommend that the IT organization target an 8% to 10% ratio of IT staff to total CFPB staff.

CFPB should form an IT program management office (PMO) to facilitate a continuation of its customer focus and implementation of key systems. Adopting a PMO approach would provide a means of standardizing artifacts across projects and facilitate development of a project database to support evaluations and a “lessons learned” process.

CFPB should initiate a formal evaluation process for IT investments. We found that the

project selection and project control components of CFPB’s IT investment management process met GAO standards, as defined in the Information Technology Investment Management (ITIM) Framework. We recommend that CFPB initiate a formal investment evaluation process, now that it has a growing set of historical data regarding the performance of IT projects. The evaluation process should be a function of the IRB and supported by the PMO.


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CFPB’s IT investment management process is operating at “stage two” of the five-stage

maturity model defined by the GAO’s ITIM Framework. In order to progress to stage three, CFPB should build upon existing IRB processes, with an emphasis on: (1) grouping similar investments together and developing an IT portfolio; (2) creating and maintaining portfolio selection criteria; (3) examining the merits of each IT investment in the context of the portfolio; and (4) using an Enterprise Architecture to help align IT investments with strategic objectives.

CFPB should develop and apply standard methods to manage risk and cost variance for IT investments. Using the Federal IT Dashboard as a performance standard to evaluate three projects, we found evidence of good requirements management, contractor oversight, human capital, and schedule management. We recommend that the IT department apply a standard method to monitor and manage cost variance, even though many projects are performed on a fixed cost basis. Also, we recommend that CFPB adopt a standardized approach to documenting risks and mitigation strategies.

1.4.5 Key Findings and Recommendations: Communications and Transparency

CFPB should continue to move toward filling positions and offices mandated by the Dodd-Frank Act. The Dodd-Frank Act mandated the creation of six offices that perform communications functions. CFPB has fulfilled its statutory mandates with respect to these positions. The CFPB is statutorily unable to create a Consumer Advisory Board (CAB) until a Director has been approved by Congress. However, a detailee is on staff currently serving in the Ombudsman role, which does not require a Director in place. In addition to filling the Ombudsman position with a permanent employee as soon as possible, we recommend that CFPB continue to move forward with developing plans for CAB and be prepared to staff positions as soon as a Director is approved.

CFPB should further coordinate its mission, vision and values statements across mediums. Currently, the CFPB has defined its mission, vision and values, but they differ slightly across platforms. While slight variances are to be expected given the differing audiences each CFPB office is trying to reach (e.g., lawmakers, consumers and the general public), in places where the CFPB’s statutory purpose, mission, vision, and values are printed, it should consider reducing inconsistencies. Doing so will build brand strength over time and allow multiple audiences to fully understand how the CFPB views itself.

CFPB should continue work on developing additional language capabilities. The CFPB has made efforts to engage populations that have been most severely impacted by the financial crisis. Currently the CFPB offers its 800 number in 189 languages and is in the process of co-developing a Spanish version of the new single mortgage disclosure document from the Know Before You Owe initiative and a fully functional Spanish version of the website. Co-developing materials takes longer but it creates a much better product for consumers. CFPB should continue to move forward in developing additional language capabilities to allow all of its key constituencies to participate in the dialogue.


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CFPB should maintain policymaker interaction. Discussions with CFPB stakeholders revealed a proactive view toward interacting with policymakers, including members of Congress, and state and local officials. Members of the CFPB team have testified before Congress on eleven occasions, have made numerous trips to the Hill to brief both Congressional staff and members of Congress, and regularly provide updates on news coming out of the bureau. CFPB should continue to engage policymakers and work toward establishing a two-way dialogue through which both the bureau and policymakers can gain important insight from one another.

CFPB should continue to engage key audiences. One of the challenges for the CFPB as it

continues to grow, mature and assume more responsibility is to continue the high level of engagement it has fostered thus far. The bureau has set a very high standard for itself and may encounter difficulties living up to that standard. An increase in staff will assist in meeting the growing responsibilities of the bureau in this area.

CFPB should develop searchable content capability. One of Community Affairs’ goals is

to have searchable resource content available for all reports, studies and communications with key groups. Community Affairs is currently working with the IT department to develop the digital infrastructure needed for such a resource. CFPB should continue to develop this capability.

1.4.6 Key Findings and Recommendations: Budget

CFPB has addressed all relevant budgeting requirements under Title X of the Dodd-Frank Act. Overall, we found that CFPB practices are documented and consistently performed.

CFPB should complete policy and procedural documentation. CFPB should continue its work underway to more-fully document policies related to critical aspects of the Federal Reserve funding request and transfer process. In addition, CFPB should continue to more-fully document policies related to budget formulation and execution / commitment control. Supplemental documentation should be developed to define detailed funding and budgetary procedures, roles and responsibilities, and performance management and monitoring practices.

CFPB should build a staffing plan for the budget organization. CFPB has been hiring additional budget staff over the past several months. As the bureau continues to expand its operations, we encourage the bureau to continue to reach out to other comparable U.S. federal agencies that have unique funding mechanisms and missions similar to that of CFPB (e.g., FDIC and OCC) to garner ideas and recommendations for the structure and staffing levels of the bureau’s budgeting operations.

CFPB should continue to expand transparency of funding and expenditures. As the CFPB grows, we expect the bureau will continue to expand the amount of information available to the public (e.g., operational plans, funding levels, expenditures, financial performance management against bureau priorities, and the like).


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CFPB should increase automation of budget formulation and performance management. As is expected, much of CFPB’s budget formulation process is manual and leverages spreadsheets – some of which are quite large and complex. CFPB should continue comparative analysis with other similar agencies to evaluate options for enhanced budget formulation and performance management automation. Where possible, we recommend leveraging pre-existing solutions to best serve the bureau at this stage of its evolution versus developing a bureau-specific solution.

CFPB should continue to clarify and document the applicability of budget-related Circulars and Acts. CFPB continues its efforts to clarify and document the applicability to CFPB operations of various budgeting and performance management Circulars and Acts. CFPB has already adopted and will continue to integrate into its operations the principles and concepts contained within the relevant Circulars and Acts and the bureau will implement, where possible, best practice components. We support the bureau’s plans to both document and implement all applicable standards and best practices.

CFPB should incorporate “outcome” objectives in its strategic planning. We understand bureau-wide strategic plans are under development within CFPB. While this performance audit did not evaluate the progress nor content of the current draft plans, we encourage CFPB’s progressive stages of strategic planning to incorporate Government Performance and Results Act (GPRA) Modernization Act of 2010 (Public Law 111-352 or GPRA-MA) concepts outlining high-level organizational priorities, “outcome” objectives, annual performance management plans, the relationship to funding and budgetary plans, progress review plans, accountability assignments, and plans for transparent monitoring and reporting.

CFPB should load its budget at a divisional level. Starting with the FY 2013 President’s Budget (currently being formulated) and the FY 2012 Operations Plan for CFPB, the bureau plans to construct its budget on a bottom-up basis by cost center. For the FY 2012 Operations Plan, CFPB plans to load its budget in its financial management system on a divisional basis for enhanced execution and control. We support the bureau’s plan to begin loading the budget at a divisional level in FY 2012 for more effective management, control and accountability.


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Section 2: Human Capital and Organizational Development

2.1 Scope of Audit

In this section, we establish scope boundaries for our audit of CFPB’s performance in the area of Human Capital and Organizational Development. In order to define the overall scope of this review area, we look to standards established by the Office of Personnel Management (OPM)’s Human Capital Assessment and Accountability Framework (HCAAF). The HCAAF establishes and defines five human capital systems that together provide a single, consistent definition of human capital management for the Federal Government. Moreover, the HCAAF outlines an ongoing process of human capital management for Federal agencies. This framework is used to maximize planning and goal setting, implementation, and evaluation of results across the following five systems:

1. Strategic Alignment (Planning and Goal Setting). Led by senior management—typically the Chief Human Capital Officer (CHCO)— to promote the alignment of human capital management strategies with bureau mission, goals, and objectives through analysis, planning, investment, measurement, and management of human capital programs.

2. Leadership and Knowledge Management (Implementation). Ensures continuity of leadership by identifying and addressing potential gaps in effective leadership, and implements and maintains programs that capture organizational knowledge and promote learning.

3. Results-Oriented Performance Culture (Implementation). Promotes a diverse, high-

performing workforce by implementing and maintaining effective performance management systems and awards programs.

4. Talent Management (Implementation). Addresses competency gaps, particularly in

mission-critical occupations, by implementing and maintaining programs to attract, acquire, develop, promote, and retain quality talent.

5. Accountability (Evaluating Results). Contributes to bureau performance by monitoring and

evaluating the results of its human capital management policies, programs, and activities; by analyzing compliance with merit system principles; and by identifying and monitoring necessary improvements.

Given its brief organizational history, it is not expected that the CFPB would have demonstrated progress across all of the systems defined by the HCAAF. Indeed, when standing up a new organization, there are generally some human capital systems and processes that are implemented prior to others. With that in mind, the scope of our audit is limited to three of the five HCAAF dimensions: Leadership and Knowledge Management; Results-Oriented Performance Culture; and Talent Management.


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The other two dimensions (Strategic Alignment and Accountability) are generally matured once an organization has established foundational human capital systems. Strategic plans for the CFPB are expected to be developed in FY 2012. The development of the strategic plan will align the mission, goals and objectives of the bureau and establish how the human capital organization will be analyzed. Accountabilities will also be developed to support analysis of program performance. In cases where the CFPB has already demonstrated progress or documented future-state plans, those activities are mapped to the corresponding HCAAF dimension, and performance is evaluated relative to established criteria. For those HCAAF dimensions where the bureau has not yet demonstrated progress, the performance audit provides general recommendations regarding: (1) target dates for achieving specific milestones in these dimensions; (2) best practices with respect to performance in these dimensions; and (3) future audits of performance in these areas. As an example, each agency is required by OPM to prepare a Strategic Human Capital Plan (SHCP) and a Human Capital Management Report (HCMR). CFPB is not required to submit the SHCP this year but is required to submit an HCMR documenting the bureau’s progress on December 15th. Thus, while a review of the SHCP is out of scope for this audit, we provide guidance regarding best practices in the development of this plan, as well as recommendations for prospective audits of performance.

2.2 Evaluation Criteria

The purpose of this section is to describe the evaluation criteria for this review area (associated findings and recommendations are presented in Section 2.3). As with other areas of performance, our audit focuses on three sets of criteria: (1) compliance with legal requirements; (2) achievement of organizational goals; and (3) alignment with performance standards, best practices, and/or benchmarks.

2.2.1 Compliance with the Law

In order to assess compliance with legal requirements, we evaluate the extent to which CFPB has met each of the following legal requirements, established by the Dodd-Frank Act and other relevant legislation.

Section 1067 of the Dodd-Frank Act requires the bureau to submit an annual report to the

Committee on Banking, Housing, and Urban Affairs of the Senate and the Committee on Financial Services of the House of Representatives that includes: (1) a Recruitment and Retention Plan; (2) a Training and Workforce Development Plan; and (3) a Workforce Flexibilities Plan.

Section 1013 of the Dodd-Frank Act requires that, “The Director shall at all times provide compensation (including benefits) to each class of employees that, at a minimum, are comparable to the compensation and benefits then being provided by the Board of Governors for the corresponding class of employees.”

Pursuant to the Dodd-Frank Act, the CFPB has collaborated with the six transferring agencies to establish procedures and systems that allow for employees transferring into the bureau to retain appropriate benefits provided to them by their prior agency for a one-year period, and to reimburse those agencies as required by the Dodd-Frank Act. The six agencies are the


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Department of Housing and Urban Development, Office of Thrift Supervision, Office of the Comptroller of the Currency, National Credit Union Administration, Federal Deposit Insurance Corporation, and the Federal Reserve Board of Governors and Federal Reserve System Banks.

Under the Dodd-Frank Act CFPB must establish business units in the areas of research, community affairs and collecting and tracking complaints. The Dodd-Frank Act states that the following offices should be developed within one year of the designation transfer date of July 21, 2011 to include, fair lending and enforcements, financial education, servicemembers affairs; and within 180 days of the transfer date, offices such as, financial protection for older Americans and minority and women inclusion, ombudsman, and consumer advisory board should be established.

2.2.2 Achievement of Organizational Goals

In order to assess achievement of organizational goals, we evaluated the progress that CFPB has made towards measurable goals that are documented in the bureau’s planning artifacts. The bullets below describe the four organizational goals that were provided by CFPB leadership:

Conduct organization design and workforce strategy development.

Design and implement a payroll and hiring system.

Pursue transfer agreements with other federal agencies currently performing consumer protection functions.

Staff up the bureau’s critical leadership positions and core functions.

2.2.3 Alignment with Performance Standards and Best Practices

We use OPM’s HCAAF framework to conduct a broad-based evaluation of the CFPB’s performance in the area of Human Capital and Organizational Development. Below, we describe the three dimensions or “systems” of HCAAF that are the focus of our evaluation, along with specific evaluation criteria for each. Each HCAAF system is based on critical success factors that make up the overall system. Critical success factors are the areas on which agencies and human capital practitioners should focus to achieve a system’s standard for success principles. Each critical success factor comprises key elements that can be examined to determine organizational development and human capital system maturity. These critical success factors, and the associated key elements, serve as evaluation criteria for our performance audit, within each HCAAF system. For a comprehensive list of critical success factors and key elements, please refer to Office of Personnel Management’s HCAFF Resource Center at the following link: http://www.opm.gov/hcaaf_resource_center/. Leadership and Knowledge Management System

The Leadership and Knowledge Management System focuses on identifying and addressing leadership competencies so that continuity of leadership is ensured, knowledge is shared across the


14

organization, and an environment of continuous learning is present. This system comprises five critical success factors and their key elements.

1. Leadership Succession Management

2. Change Management

3. Integrity and Inspiring Employee Commitment

4. Continuous Learning

5. Knowledge Management

Results-Oriented Performance Culture System

The Results-Oriented Performance Culture System focuses on having a diverse, results-oriented, high-performing, workforce, as well as a performance management system that effectively plans, monitors, develops, rates, and rewards employee performance. This system comprises six critical success factors and their key elements.

1. Communications

2. Performance Appraisal

3. Awards

4. Pay-for-Performance

5. Diversity Management

6. Labor/Management Relations

Talent Management System

The Talent Management System focuses on agencies having quality people with the appropriate competencies in mission-critical activities. This system comprises two critical success factors and their key elements.

1. Recruitment

2. Retention


In this section, we present key findings and recommendations for each of the three sets of criteria included in the performance audit: (1) compliance with the legal requirements; (2) achievement of organizational goals; and (3) alignment with performance standards, best practices, and/or benchmarks. The supporting tables referenced throughout this section are presented at the end of the section.

2.3.1 Compliance with Legal Requirements

Table 1 presents our assessment of the CFPB’s compliance with legal requirements. Each row in this table specifies a legal requirement for the CFPB. For each legal requirement, we describe the progress that the bureau has demonstrated to date, along with recommendations (as applicable) for future action. The section below highlights our key findings and recommendations:


15

CFPB fully complied with the requirement to develop a Recruitment and Retention Plan, Training and Workforce Development Plan and Workforce Flexibilities Plan. CFPB delivered these plans to Congress on July 21, 2011, as part of the report Developing our Human Capital. The document identifies achievements as well as near and longer term actions in each of the three requirement areas.

CFPB met the requirement of the Dodd-Frank Act to develop a compensation and benefits program. CFPB benchmarked the Federal Reserve Board and other FIRREA agencies to come up with a comparable and competitive compensation model to attract mission-critical and support occupations. Retirement and non-retirement benefits were benchmarked across government agencies to develop benefits and programs that are progressive and timely. Thorough analysis led to developing compensation models and a benefits package that goes beyond the limitations of Title V.

CFPB leveraged best practices in developing procedures for employee transfers. CFPB drew on information from the report Research & Analysis: Organizational Stand-ups Lessons Learned and Key Insights to guide the development of procedures for transferring employees from other agencies. Specifically, this report describes a case study of the Federal Housing Finance Agency (FHFA), which underscores the importance of understanding the legislative requirements for transfer employees. The FHFA encountered a significant roadblock in numerous OMB and OPM regulations on government employee transfers, and struggled with the maze of federal regulations while trying to achieve organizational goals. CFPB found that although negotiating MOUs with six transferring agencies was a lengthy process, the value of transferred employees from other federal agencies was significant. CFPB established a centralized recruitment and outreach process to identify, interview and select federal employees for its mission-critical Examiner and Consumer Response positions. This system helped CFPB to successfully attract and negotiate the transfer of highly-skilled employees from other Federal agencies between July and October 2011.


Table 2 presents our assessment of the CFPB’s achievement of organizational goals. Each row in this table corresponds to a specific CFPB organizational goal. For each goal, we describe the progress that the bureau has demonstrated to date, along with recommendations for future action (as necessary). The section below highlights our key findings and recommendations for each goal.

CFPB established an organizational design and a workforce plan and approach. This goal was completed in the following ways: o CFPB developed a preliminary organizational design composed of six units, and an

overall targeted head count of 1325 employees. To accompany the organizational design each unit developed vision and functional statements.

o CFPB units were tasked to implement staffing and hiring actions such as determining the number and type of positions for each level. Position descriptions were developed for each position; vacancy announcements developed and job vacancies were advertised in USAJOB.


16

CFPB designed and implemented a payroll and hiring system. This goal was completed in the following ways: o In compliance with the Dodd-Frank Act requiring that CFPB’s compensation system be

comparable to that of the Federal Reserve Board, CFPB designed a compensation approach and model based on benchmark studies of the Federal Reserve Board compensation approach and model as well as other FIRREA agencies.

o Benefits packages were benchmarked from the same agencies and included both retirement and non-retirement benefits. The CFPB benefits package goes beyond the typical federal benefits package by offering benefits such as short- and long-term disability, dental and vision benefits, business travel accident insurance, and a flexible spending account.

o CFPB designed their hiring system by classifying jobs of most critical positions first, creating a job leveling system, including pay bands. The hiring system classified required positions, starting with the most critical positions.

o A major task in CFPB’s launch was to set up payroll and human resource transaction systems. The National Finance Center’s (NFC) payroll system and the Department of Treasury’s personnel system, HR Connect, were chosen and implemented. Many of the Dodd-Frank transfer agencies use the NFC finance system; thus, the use of this system by CFPB facilitated the employee transfer process to CFPB.

CFPB has transferred employees from other federal agencies to address mission-critical

staffing needs. CFPB identified the major mission-critical and supporting functional positions required, and negotiated with six federal agencies for positions to support mission-critical functions being transferred to CFPB. A memorandum of understanding (MOU) was developed that specifies the agreement with the federal agencies to transfer employees into CFPB. An ‘Expression of Interest’ was implemented with federal agencies, and interviewing and selection criteria were outlined in MOUs, resulting in 232 transferees into CFPB.

CFPB should staff up the bureau’s leadership positions and core functions. This goal is

mostly complete. To date, 4 of the 6 Associate Directors are on board and 20 of the 36 Assistant Directors are on board. Going forward, it is important to continue the search to fill needed leadership positions in a timely manner. The following activities were completed for this goal: o CFPB identified and detailed federal employees to serve on an implementation team

which carried out initial planning and execution of core functions and leadership needs. o The implementation team developed a hiring process by meeting with its members to

define competencies for Associate Directors. Associate Directors were hired and the same process was performed to define competencies for and to hire Assistant Directors. Assistant Directors defined competencies for mission critical positions such as Examiners, Research & Market Analysts, Economists, and Financial Analysts. Thus, the key mission-critical functions and supporting populations were hired into CFPB in a cascading fashion.

o Key hiring policies were implemented, such as policy number CFPB-COO-011 (Excepted Service Non-Executive Positions under Waiver Authority Interim Policy). This policy describes the methodology and authorities the CFPB will use to create, evaluate, and fill non-executive positions that are excepted from the competitive service, pursuant to the waiver provision in § 1013(a)(1)(C) of the Consumer Financial Protection Act of 2010.


17

o Going forward, it is important to continue the search for the balance of the Associate and Assistant Directors to fill needed leadership positions in a timely manner. Associate and Assistant Directors have an important role as leaders to set actions for their units to accomplish the short and long-term goals set for the CFPB as a new bureau with high visibility. This should be a priority search for CFPB and goals should be set for Assistant Directors to be hired within the first two quarters of the FY 2012 fiscal year.


Table 3, Table 4 and Table 5 present our assessment of the CFPB’s alignment with performance standards and best practices. Each row in these tables corresponds to a specific critical success factor within the corresponding HCAAF system. For each critical success factor, we provide the following information: (1) a rating of CFPB’s performance to date, using a stoplight scale (i.e., Red, Yellow or Green); (2) a summary of demonstrated performance; (3) the priority of future progress in this area, based on the importance of the performance area for a start-up organization; and (4) recommendations for future action. Table 6 presents high-level recommendations for the two HCAAF Systems (Strategic Alignment and Accountability) that are outside the scope of this audit. The section below highlights our key findings and recommendations—those that are the most critical at this time for the CFPB’s Human Capital Office. They are derived from the findings that are “High” priorities in the matrices on the following pages.

CFPB should develop a formal Human Capital Program Plan, which would build on existing projects and systems. The Human Capital Office is in a start-up mode and has multiple human capital systems that have been designed or are planned to be implemented in FY 2012. It is important for the Human Capital Office to formalize their various plans and projects by developing a Human Capital Program Plan (HCPP). The HCPP is a functional plan that will integrate the Human Capital Office vision and mission and strategic goals for CFPB. Use of the HCAAF standards set by OPM is a good framework to comply with legal and federal standards and also used as a guide. A formal plan should be developed in the near term and led/managed by the Chief Human Capital Officer (CHCO) or similar position in the Human Capital Office to oversee and make decisions about Human Capital projects within the HCPP. The objective of an HCPP will be to coordinate all major human capital systems, some of which are already in progress; some of which need an implementation strategy; and other systems are still in a formative stage. The systems that will be part of the HCPP include, but are not limited to:

o Human Capital Strategy and Implementation plan o Executive/Management Development Program and Succession Management system o Training and Workforce Development Program o Knowledge Management System o Performance Management System including a pay-for-performance and awards

programs o Cornerstone On-Demand system that facilitates implementation of the: performance

system, learning management system, knowledge management system, and integrated talent management system.

o Diversity Plan o Long-term Recruitment Plan


18

o Retention Plan

CFPB has followed best practices in organizational transformation through the creation of a “Culture Club”. A GAO report on Results-Oriented Cultures (GAO-03-669) highlights the importance of involving employees from the beginning in transformation efforts. CFPB has done just that with forming a Culture Club. The Culture Club has researched progressive approaches, held lunch and learns to communicate information; and completed surveys such as the Values survey and the Demographics and diversity survey. The GAO report states that creating opportunities for employees helps to accelerate the transformation and in CFPB’s case, establishing a work environment that provides ample communications, innovation and creativity. This is a unique opportunity for CFPB as a start up bureau to create an environment that is characterized by the values of open communications and shared responsibility for accomplishing organizational goals and objectives. While the Culture Club has had many accomplishments they need a formal charter establishing the Culture Club as an organization with a purpose and process to continue the energy, creativity, and activity establishing the work they will be doing in months and years to come. The Culture Club charter should consider the following:

o Set a Culture Club vision, case for change to establish raison d'être for the Culture

Club. This statement will explain the purpose and objectives for the group. o Gain executive sponsorship – who will be the sponsor and what is their role and

responsibility as leader/s? o Establish membership and representation from all CFPB units and expertise – who are

the members, how are they chosen, what are their responsibilities, how long is their tenure; do members rotate?

o Develop multiple outreach methods – lunch and learns are excellent forms of communicating and training on important topics there are additional methods to exchange ideas. Determine the various outreach methods and how outreach, communications, training can increase morale and bureau engagement.

o Uncover important information that is not spoken or shared in formal sessions. Identify methods for anonymous input to provide for broader representation of ideas and diversity of information.

o Develop a Culture Club project plan that is communicated to CFPB and seeks broad input.

CFPB should continue to implement its recruitment strategy. CFPB has done an excellent job at filling positions to stay on target with recruiting goals and should continue aggressive recruiting efforts through FY 2012 to hire the balance of personnel to staff CFPB at its targeted level. It is important that CFPB follow through by implementing its recruitment strategy, vision and goals stated in the September 23, 2011 presentation: CFPB Recruitment Strategy & Update. There are over 400 mission critical vacancies and a number of outreach activities that have been identified for FY 2012. This is a big effort for the CFPB Human Capital Office this year and one that can be accomplished by following through with the strategy and action plans to support the challenges that have been defined in the presentation. There are over 25 actions suggested. Some are complex efforts that coordinate detailed plans


19

and groups of personnel. Dedication, commitment, coordination and expertise will be needed at all levels to accomplish these actions. In the near term consider the following actions:

o Building the recruitment infrastructure of specialists and CFPB workforce will be significant to accomplishing the outreach efforts, plans and multiple actions.

o Identify a project manager to lead the effort and set clear expectations and accountabilities.

o Consider detailing CFPB staff into recruitment efforts on a rotational basis and provide a form of benefit for their contribution; possibly a letter for their file sent to their manager showing commitment and dedication.

o Evaluate results and update strategy, goals and plans to stay as much on track as possible.

CFPB should fully develop a Training and Workforce Development Plan. The Dodd-

Frank Act specifically calls for a Training and Workforce Development plan, and this continues to be a high priority and immediate need for CFPB. In the Annual Report to Congress on July 21, 2011, Developing our Human Capital, CFPB defined an approach to training and workforce development. To support their mission, CFPB has developed and held lunch and learns, on-boarding training, and approximately three weeks of training for the core Examiner and Consumer Response workforces. An assessment of workforce skills has been executed and core competencies for executives and non-executives have been developed. CFPB has a longer term goal to develop as a learning organization. In the near term, the Training and Workforce Development Plan should ensure that CFPB has a consistent and unified approach to training and workforce development, across all units and employee populations. Some near term activities to include in the Training and Workforce Development Plan:

o Apply competency models to develop career paths. o Identify a skills matrix for each family of positions and for each level. o Plan and implement the Emerging Leader or Executive Candidate Development

Program. o Plan and implement an Executive Management Development Program.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

20

Tab

le 1

: C

omp

lian

ce w

ith

Leg

al R

equ

irem

ents

Lega

l Req

uire

men

t De

mon

stra

ted

Perfo

rman

ce

Find

ing

/ Rec

omm

enda

tion

Sect

ion

1067

of t

he D

odd-

Fran

k Ac

t req

uire

s th

e bu

reau

to s

ubm

it an

annu

al

repo

rt to

the

Com

mitte

e on

Ban

king,

Hou

sing,

and

Urb

an A

ffairs

of t

he S

enat

e an

d th

e Co

mm

ittee

on F

inan

cial S

ervic

es o

f the

Hou

se o

f Rep

rese

ntat

ives

that

in

clude

s: (1

) a R

ecru

itmen

t and

Ret

entio

n Pl

an; (

2) a

Tra

inin

g an

d W

orkf

orce

De

velo

pmen

t Pla

n; a

nd (3

) a W

orkf

orce

Fle

xibilit

ies

Plan

.

Annu

al R

epor

t To

Cong

ress

, Jul

y 21

, 201

1: D

evel

opin

g ou

r Hu

man

Cap

ital--

•

Recr

uitm

ent a

nd R

eten

tion

Plan

•

Trai

ning

and

Wor

kfor

ce D

evel

opm

ent P

lan

• W

orkf

orce

Fle

xibilit

ies

Plan

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Sect

ion

1013

of t

he D

odd-

Fran

k Ac

t req

uire

s th

at, “

The

Dire

ctor

sha

ll at a

ll tim

es

prov

ide

com

pens

atio

n (in

cludi

ng b

enef

its) t

o ea

ch c

lass

of e

mpl

oyee

s th

at, a

t a

min

imum

, are

com

para

ble

to th

e co

mpe

nsat

ion

and

bene

fits th

en b

eing

pro

vided

by

the

Boar

d of

Gov

erno

rs fo

r the

cor

resp

ondi

ng c

lass

of e

mpl

oyee

s.”

Deve

lope

d an

d im

plem

ente

d co

mpe

nsat

ion

and

bene

fits

prog

ram

s th

at m

et th

e re

quire

men

t of t

he D

odd-

Fran

k Ac

t. No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce e

lem

ent

Purs

uant

to th

e Do

dd-F

rank

Act

, the

CFP

B ha

s co

llabo

rate

d wi

th th

e six

tra

nsfe

rring

age

ncie

s to

est

ablis

h pr

oced

ures

and

sys

tem

s th

at a

llow

for

empl

oyee

s tra

nsfe

rring

into

the

CFPB

to re

tain

app

ropr

iate

ben

efits

pro

vided

to

them

by

thei

r prio

r age

ncy

for a

one

-yea

r per

iod,

and

to re

imbu

rse

thos

e ag

encie

s as

requ

ired

by th

e Do

dd-F

rank

Act

. The

six

agen

cies

are:

the

Depa

rtmen

t of H

ousin

g an

d Ur

ban

Deve

lopm

ent,

Offic

e of

Thr

ift Su

perv

ision

, O

ffice

of th

e Co

mpt

rolle

r of t

he C

urre

ncy,

Nat

iona

l Cre

dit U

nion

Adm

inist

ratio

n,

Fede

ral D

epos

it Ins

uran

ce C

orpo

ratio

n, a

nd th

e Fe

dera

l Res

erve

Boa

rd o

f G

over

nors

and

Fed

eral

Res

erve

Sys

tem

Ban

ks.

Esta

blish

ed a

nd im

plem

ente

d a

cent

raliz

ed re

crui

tmen

t and

ou

treac

h pr

oces

s fo

r the

iden

tifica

tion,

recr

uitm

ent,

inte

rvie

wing

and

sel

ectio

n of

indi

vidua

ls. N

egot

iate

d an

d im

plem

ente

d m

emor

anda

of u

nder

stan

ding

(MO

Us) w

ith th

e De

partm

ent o

f Hou

sing

and

Urba

n De

velo

pmen

t, Fe

dera

l De

posit

Insu

ranc

e Co

rpor

atio

n, F

eder

al R

eser

ve S

yste

m,

Natio

nal C

redi

t Uni

on A

dmin

istra

tion,

Offic

e of

the

Com

ptro

ller

of th

e Cu

rrenc

y, a

nd th

e O

ffice

of T

hrift

Supe

rvisi

on, t

o tra

nsfe

r em

ploy

ees

to th

e CF

PB. M

OUs

inclu

de p

roce

sses

an

d pr

oced

ures

for m

anag

ing

trans

ferra

ble

bene

fits u

nder

the

Dodd

-Fra

nk A

ct.

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Unde

r the

Dod

d-Fr

ank

Act C

FPB

mus

t est

ablis

h bu

sines

s un

its in

the

area

s of

re

sear

ch, c

omm

unity

affa

irs a

nd c

olle

ctin

g an

d tra

ckin

g co

mpl

aint

s. T

he D

odd-

Fran

k Ac

t sta

tes

that

the

follo

wing

offic

es s

houl

d be

dev

elop

ed w

ithin

one

yea

r of

the

desig

natio

n tra

nsfe

r dat

e of

Jul

y 21

, 201

1 to

inclu

de, f

air l

endi

ng a

nd

enfo

rcem

ents

, fin

ancia

l edu

catio

n, s

ervic

emem

bers

affa

irs; a

nd w

ithin

180

day

s of

the

trans

fer d

ate,

offic

es s

uch

as, f

inan

cial p

rote

ctio

n fo

r old

er A

mer

icans

and

m

inor

ity a

nd w

omen

inclu

sion,

om

buds

man

, and

con

sum

er a

dviso

ry b

oard

sh

ould

be

esta

blish

ed.

Deve

lope

d an

d im

plem

ente

d a

work

forc

e pl

an a

nd

orga

niza

tiona

l stru

ctur

e th

at in

clude

s al

l the

units

and

offic

es

requ

ired

by th

e Do

dd-F

rank

Act

.

Hire

per

sonn

el to

dire

ct a

nd im

plem

ent

the

offic

es a

nd u

nits

func

tions

as

requ

ired

by th

e Do

dd-F

rank

Act

.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

21

Tab

le 2

: Ach

ieve

men

t of O

rgan

izat

iona

l Goa

ls

Org

aniz

atio

nal G

oals

De

mon

stra

ted

Perfo

rman

ce

Find

ing

/ Rec

omm

enda

tion

Cond

uct o

rgan

izatio

n de

sign

and

work

forc

e st

rate

gy d

evel

opm

ent.

• CF

PB d

evel

oped

a p

relim

inar

y or

gani

zatio

nal d

esig

n co

mpr

ised

of s

ix un

its.

• Ea

ch C

FPB

unit d

evel

oped

visi

on a

nd fu

nctio

nal s

tate

men

ts.

• CF

PB u

nits

wer

e ta

sked

to d

eter

min

e th

e nu

mbe

r and

type

of p

ositio

ns a

t eac

h le

vel; d

evel

op p

ositio

n de

scrip

tions

, vac

ancy

ann

ounc

emen

ts, jo

b va

canc

ies

to

adve

rtise

in U

SAJO

B.

• Id

entify

gap

s be

twee

n pr

ojec

ted

or a

ctua

l ava

ilabi

lity

of th

e CF

PB’s

miss

ion-

critic

al c

ompe

tenc

ies

and

the

curre

nt a

nd fu

ture

dem

ands

.

Desig

n an

d im

plem

ent a

pay

roll a

nd h

iring

syst

em.

• CF

PB d

esig

ned

a co

mpe

nsat

ion

appr

oach

and

ben

efits

pac

kage

s ba

sed

on

benc

hmar

ks fr

om F

eder

al R

eser

ve B

oard

and

oth

er F

IRRE

A ag

encie

s fo

r co

mpe

nsat

ion

mod

els

as id

entifi

ed in

Dod

d-Fr

ank

Act.

•

CFPB

des

igne

d th

eir h

iring

syst

em b

y cla

ssify

ing

jobs

of m

ost c

ritica

l pos

itions

first

, cr

eatin

g jo

b le

vels

by s

tarti

ng w

ith G

S Sc

hedu

le a

nd d

evel

opin

g a

CFPB

mod

el

with

Pay

Ban

ds.

• CF

PB re

alize

d th

at to

tran

sfer

em

ploy

ees

from

one

fede

ral a

genc

y to

CFP

B th

ey

need

ed to

set

up

a pa

yrol

l pro

vider

. The

Nat

iona

l Fin

ance

Cen

ter (

NFC)

and

pe

rson

nel s

yste

m, H

R Co

nnec

t, we

re c

hose

n.

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce

elem

ent

Purs

ue tr

ansf

er a

gree

men

ts w

ith o

ther

fe

dera

l age

ncie

s cu

rrent

ly pe

rform

ing

cons

umer

pro

tect

ion

func

tions

.

• CF

PB id

entifi

ed th

e m

ajor

miss

ion-

critic

al a

nd s

uppo

rting

func

tiona

l pos

itions

. •

CFPB

dev

elop

ed a

mem

oran

dum

of u

nder

stan

ding

to n

egot

iate

with

six

fede

ral

agen

cies

to tr

ansf

er e

mpl

oyee

s.

• Ag

reem

ents

with

five

fede

ral a

genc

ies

were

neg

otia

ted

and

the

proc

ess

for

trans

ferri

ng e

mpl

oyee

s wa

s es

tabl

ished

and

impl

emen

ted.

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce

elem

ent

Staf

f up

the

bure

au’s

critic

al le

ader

ship

po

sitio

ns a

nd c

ore

func

tions

.

• CF

PB id

entifi

ed a

nd d

etai

led

fede

ral e

mpl

oyee

s to

ser

ve o

n an

impl

emen

tatio

n te

am to

hel

p st

and-

up C

FPB.

•

The

impl

emen

tatio

n te

am d

evel

oped

a h

iring

proc

ess.

The

y m

et w

ith O

rgan

izatio

n O

fficer

s to

def

ine

com

pete

ncie

s fo

r Ass

ocia

te D

irect

ors.

Ass

ocia

te D

irect

ors

were

hi

red

and

the

sam

e pr

oces

s wa

s pe

rform

ed to

def

ine

com

pete

ncie

s fo

r Ass

istan

t Di

rect

ors.

•

Assis

tant

Dire

ctor

s de

fined

com

pete

ncie

s fo

r miss

ion-

critic

al a

nd s

uppo

rting

po

pula

tions

for h

iring

core

func

tions

.

• St

aff

the

vaca

nt c

ritica

l lead

ersh

ip p

ositio

ns

• De

velo

p a

long

-term

recr

uitm

ent p

lan.

•

Long

-term

recr

uitin

g ef

forts

to fo

cus

on a

cqui

ring

spec

ializ

ed c

ompe

tenc

ies

nece

ssar

y to

roun

d ou

t wo

rkfo

rce

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

22

Tab

le 3

: Alig

nmen

t wit

h P

erfo

rman

ce S

tand

ards

(Lea

ders

hip

and

Kno

wle

dge

Man

agem

ent S

yste

m)

Fact

or

Scor

e Su

mm

ary

of P

erfo

rman

ce

Prio

rity

Find

ing

/ Rec

omm

enda

tion

Lead

ersh

ip

Succ

essio

n M

anag

emen

t

Key

acco

mpl

ishm

ents

inclu

de: (

1) D

esig

ned

and

appl

ied

the

Succ

essio

n M

anag

emen

t App

arat

us to

cap

ture

dat

a of

lead

ersh

ip

work

forc

e, p

roje

ctio

n of

attr

ition

for t

erm

app

oint

men

ts;(2

) Use

d th

e Ex

ecut

ive C

ore

Qua

lifica

tions

(ECQ

s) a

s a

basis

for d

evel

opin

g CF

PB E

xecu

tive

Com

pete

ncie

s; (3

) Ass

esse

d an

d pu

rcha

sed

succ

essio

n m

odul

e in

per

form

ance

tool

.

Low

De

velo

p Ex

ecut

ive/M

anag

emen

t Dev

elop

men

t Pro

gram

.

En

sure

ava

ilabi

lity o

f tra

ined

men

tors

to s

uppo

rt ne

w an

d pr

ospe

ctive

lead

ers;

and

em

ploy

ees

in d

evel

opm

ent p

rogr

ams.

Chan

ge

Man

agem

ent

Key

acco

mpl

ishm

ents

inclu

de: (

1) C

ultu

re c

lub

esta

blish

ed to

co

ordi

nate

and

pre

sent

lunc

h an

d le

arns

to c

omm

unica

te c

hang

e,

bran

ding

, eng

age

empl

oyee

s; (2

) Com

plet

ed a

dem

ogra

phics

an

alys

is to

def

ine

CFPB

dem

ogra

phics

and

dive

rsity

. (3)

Des

igne

d an

d im

plem

ente

d va

lues

and

cul

ture

wor

kpla

ce a

ctivi

ties.

High

De

fine

indi

vidua

l per

form

ance

pla

ns to

rate

lead

ers

and

man

ager

s on

thei

r im

plem

enta

tion

of c

hang

e in

itiativ

es a

s ch

ange

is o

ngoi

ng.

Do

cum

ent t

he b

urea

u’s

stra

tegy

and

pla

n fo

r com

mun

icatio

n of

ch

ange

.

Inte

grity

and

Insp

iring

Empl

oyee

Co

mm

itmen

t

Key

acco

mpl

ishm

ents

inclu

de: (

1) F

ocus

ed o

n op

en

com

mun

icatio

n by

hol

ding

mul

tiple

town

mee

tings

and

lunc

h an

d le

arns

; (2)

Com

plet

ed a

val

ues

surv

ey to

est

ablis

h co

re v

alue

s; (3

) Ne

w em

ploy

ees

atte

nd 1

.25

hour

s et

hics

trai

ning

.

Med

ium

Pa

rticip

ate

in a

n O

PM le

d, E

mpl

oyee

Vie

wpoi

nt S

urve

y to

utili

ze

a m

echa

nism

for a

nony

mou

s em

ploy

ee fe

edba

ck.

Es

tabl

ish ID

Ps in

cludi

ng te

amwo

rk, c

olla

bora

tion

and

othe

r m

echa

nism

s to

driv

e pe

rform

ance

for a

hig

hly

enga

ged

staf

f.

Cont

inuo

us L

earn

ing

Key

acco

mpl

ishm

ents

inclu

de: (

1) N

ew h

ire o

n-bo

ardi

ng p

rogr

am

esta

blish

ed u

nder

stan

ding

of h

ow to

bes

t eng

age

and

succ

eed

at

CFPB

(2) E

stab

lishe

d tra

inin

g fo

r miss

ion-

critic

al p

ositio

ns,

Exam

iner

s an

d Co

nsum

er R

espo

nse

Spec

ialis

ts; (

3) P

artn

ered

wi

th T

reas

ury

Dep

artm

ent t

o us

e th

e Tr

easu

ry L

earn

ing

Man

agem

ent S

yste

m.

High

De

velo

p CF

PB T

rain

ing

and

Wor

kfor

ce D

evel

opm

ent P

lan

that

bu

ilds

com

pete

ncie

s im

porta

nt to

stra

tegi

c go

als

and

obje

ctive

s an

d CF

PB’s

perfo

rman

ce p

lan

exec

utio

n.

Ti

e co

mpe

tenc

y m

odel

s to

indi

vidua

l dev

elop

men

t pla

ns fo

r m

issio

n cr

itical

em

ploy

ees.

Know

ledg

e M

anag

emen

t

Key

acco

mpl

ishm

ents

inclu

de: (

1) D

evel

oped

Sha

rePo

int s

yste

m

for l

ibra

ry o

f mat

eria

ls; (2

) Des

igne

d kn

owle

dge

man

agem

ent

syst

em e

nhan

cem

ents

for u

pcom

ing

perfo

rman

ce m

anag

emen

t to

ol; (

3) S

taff

parti

cipat

es in

con

fere

nces

and

com

mun

ities

such

as

in th

e re

sear

ch m

arke

ts a

nd re

gula

tions

and

Con

sum

er B

ehav

ior.

Med

ium

De

fine

the

valu

e of

sha

ring

know

ledg

e fo

r reu

se a

nd

colla

bora

tion.

Es

tabl

ish m

echa

nism

s su

ch a

s in

cent

ives

or a

requ

irem

ent o

n in

divid

ual p

erfo

rman

ce p

lans

to d

rive

use

and

reus

e da

ta

sour

ces.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

23

Tab

le 4

: A

lign

men

t w

ith

Per

form

ance

Sta

nd

ard

s (R

esu

lts-

Ori

ente

d P

erfo

rman

ce C

ult

ure

Sys

tem

)

Fact

or

Scor

e Su

mm

ary

of P

erfo

rman

ce

Prio

rity

Find

ing

/ Rec

omm

enda

tion

Com

mun

icatio

ns

Key

acco

mpl

ishm

ents

inclu

de: (

1) C

FPB’

s m

issio

n, g

oals

and

obje

ctive

s ar

e co

mm

unica

ted

in o

n-bo

ardi

ng a

nd m

ultip

le p

rogr

ams

and

com

mun

icatio

ns a

nd d

istrib

uted

in h

ard

copy

; (2)

Cul

ture

Clu

b ga

ther

s fe

edba

ck a

nd o

ther

inpu

t.

High

Es

tabl

ish a

com

mun

icatio

n st

rate

gy th

at s

hare

s th

e vis

ion,

m

issio

n, a

nd o

ther

rela

ted

docu

men

ts s

uch

as th

e Hu

man

Ca

pita

l Stra

tegi

c pl

an.

Su

rvey

em

ploy

ees

to g

athe

r dat

a th

at in

dica

tes

they

are

awa

re

of th

e st

rate

gic

plan

and

goa

ls.

Perfo

rman

ce

Appr

aisa

l

Key

acco

mpl

ishm

ents

inclu

de: (

1) D

esig

ned

com

pete

ncie

s at

all

leve

ls an

d de

velo

ped

a ra

ting

scal

e an

d co

mpe

tenc

y in

dica

tors

. (2)

De

signe

d pe

rform

ance

man

agem

ent s

yste

m fo

r im

plem

enta

tion

into

Cor

ners

tone

tool

. (3)

Fee

dbac

k “c

onve

rsat

ions

” in

lieu

of

perfo

rman

ce s

yste

m b

eing

hel

d fo

r all e

mpl

oyee

s re

gard

less

of

leng

th o

f em

ploy

men

t.

Med

ium

Es

tabl

ish d

ivisio

n go

als

that

tie to

org

aniza

tiona

l goa

ls.

In

tegr

ate

orga

niza

tion

goal

s in

to C

orne

rsto

ne p

erfo

rman

ce

man

agem

ent s

yste

m.

De

velo

p pr

oces

s fo

r dea

ling

with

poo

r per

form

ance

and

co

mm

unica

te p

roce

ss.

Awar

ds

Key

acco

mpl

ishm

ents

inclu

de: (

1) B

enef

its a

nd p

ay is

def

ined

in

on-b

oard

ing;

(2) C

ondu

cted

bes

t pra

ctice

rese

arch

foun

d in

sim

ilar

FIRR

EA a

genc

ies.

(3) P

rese

nted

cer

tifica

te o

f ach

ieve

men

t awa

rds

to th

e im

plem

enta

tion

team

and

the

Foun

der’s

Clu

b.

Low

De

sign,

com

mun

icate

and

impl

emen

t a fo

rmal

awa

rd p

rogr

am

that

alig

ns w

ith o

rgan

izatio

nal g

oals

and

valu

es.

Es

tabl

ish p

ropo

sed

awar

ds s

uch

as M

erit p

ay, S

hort-

term

in

cent

ives,

reco

gnitio

n pr

ogra

m a

nd o

ther

per

form

ance

awa

rd

prog

ram

s.

Pay

for P

erfo

rman

ce

Key

acco

mpl

ishm

ents

inclu

de: (

1) C

ompe

nsat

ion

met

hodo

logy

and

cr

eativ

e pa

y st

ruct

ures

hav

e be

en d

evel

oped

, exp

lain

ed a

nd

com

mun

icate

d br

oadl

y; (2

) Und

er th

e Do

dd-F

rank

Act

, est

ablis

hed

com

pens

atio

n an

d be

nefits

pro

gram

.

Med

ium

Es

tabl

ish c

lear

pay

dist

inct

ions

for p

erfo

rman

ce in

Cor

ners

tone

Pe

rform

ance

Man

agem

ent S

yste

m.

Co

mm

unica

te u

pdat

es, r

evisi

ons

and

perfo

rman

ce p

hilo

soph

y th

at c

reat

e in

cent

ives.

Dive

rsity

M

anag

emen

t

Key

acco

mpl

ishm

ents

inclu

de: (

1) D

evel

oped

and

pre

sent

ed C

FPB

Dem

ogra

phics

' Ana

lysis

to tr

ack

and

anal

yze

work

forc

e di

vers

ity.

(2) P

lan

for t

arge

ted

recr

uitin

g &

outre

ach

at d

ivers

ity-fo

cuse

d ev

ents

.

Med

ium

De

velo

p Di

vers

ity P

lan

and

com

mun

icatio

n th

roug

hout

CFP

B.

Pu

blish

up-

to-d

ate

polic

ies

that

indi

cate

zer

o to

lera

nce

for s

exua

l ha

rass

men

t and

disc

rimin

atio

n in

the

work

plac

e.

Labo

r Rel

atio

ns

Man

agem

ent

Key

acco

mpl

ishm

ents

inclu

de: (

1) T

he C

FPB

does

not

hav

e un

ion

activ

ity a

t thi

s tim

e, b

ut it

has

inve

sted

in s

taff

that

can

sup

port

labo

r re

latio

ns s

houl

d th

e oc

casio

n ar

ise.

N/A

Th

is is

not a

pplic

able

at t

his

time.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

24

Tab

le 5

: A

lign

men

t w

ith

Per

form

ance

Sta

nd

ard

s (T

alen

t M

anag

emen

t S

yste

m)

Fact

or

Scor

e Su

mm

ary

of P

erfo

rman

ce

Prio

rity

Find

ing

/ Rec

omm

enda

tion

Recr

uitm

ent

Key

acco

mpl

ishm

ents

inclu

de: (

1) R

ecru

ited

and

hire

d 52

5 em

ploy

ees

by 7

/31/

11 e

xcee

ding

fede

ral g

over

nmen

t tim

elin

es; (

2)

Esta

blish

ed re

crui

tmen

t pro

cess

in p

rivat

e an

d pu

blic

sect

ors

and

nego

tiate

d an

d im

plem

ente

d m

emor

anda

of u

nder

stan

ding

with

6

gove

rnm

ent a

genc

ies

to tr

ansf

er e

mpl

oyee

s to

the

CFPB

bet

ween

Ju

ly an

d O

ctob

er 2

011;

(3) D

evel

oped

a c

ompr

ehen

sive

set o

f m

etric

s to

mea

sure

hirin

g ef

fect

ivene

ss. (

4) C

ondu

cted

targ

eted

re

crui

tmen

t and

out

reac

h to

dive

rsity

sou

rces

and

sta

keho

lder

s.

High

De

velo

p lo

ng-te

rm R

ecru

itmen

t Pla

n to

: add

ress

sta

ffing

need

s an

d an

ticip

ated

gap

s in

crit

ical s

kills

and

com

pete

ncie

s; a

nd

esta

blish

per

form

ance

indi

cato

rs a

nd to

clo

se s

kill g

aps

for

miss

ion-

critic

al o

ccup

atio

ns.

De

velo

p in

nova

tive

hirin

g an

d ou

treac

h pr

ogra

ms

to a

ttrac

t ta

lent

ed a

nd s

kille

d ca

ndid

ates

from

dive

rse

back

grou

nds.

De

velo

p a

proc

ess

that

hol

ds m

anag

ers

acco

unta

ble

for

effe

ctive

and

effic

ient

recr

uitm

ent a

ctivi

ties

for t

heir

units

.

Rete

ntio

n

Key

acco

mpl

ishm

ents

inclu

de: (

1) C

FPB

has

esta

blish

ed

prod

uctiv

e, s

uppo

rtive

wor

k en

viron

men

t pro

gram

s su

ch a

s, fle

xible

wo

rk s

ched

ules

, tel

ewor

k, d

omes

tic p

artn

er b

enef

its, s

hort-

and

lo

ng-te

rm d

isabi

lity, e

mer

genc

y ch

ild c

are

serv

ices,

phy

sical

exa

m

prog

ram

, em

ploy

ee a

ssist

ance

pro

gram

and

par

enta

l leav

e be

nefits

; (2)

Tra

inin

g ha

s be

en d

evel

oped

for m

issio

n-cr

itical

oc

cupa

tions

; (3)

Inno

vativ

e co

mpe

nsat

ion

stra

tegi

es h

ave

been

de

velo

ped.

Med

ium

Expl

ore

stra

tegi

es to

reta

in m

issio

n-cr

itical

occ

upat

ions

.

De

velo

p a

rete

ntio

n pl

an.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

25

Tab

le 6

: R

ecom

men

dat

ion

s fo

r O

ut-

of-S

cop

e H

CA

AF

Sys

tem

s

HCAA

F Sy

stem

Re

com

men

datio

ns

Stra

tegi

c Al

ignm

ent S

yste

m

De

velo

p Hu

man

Cap

ital S

trate

gy th

at a

ligns

to th

e CF

PB’s

miss

ion,

goa

ls an

d ob

ject

ives

and

facil

itate

s wo

rkfo

rce

plan

ning

.

Es

tabl

ish a

stra

tegi

c pa

rtner

ship

with

Hum

an R

esou

rce

for w

orkf

orce

pla

nnin

g.

De

velo

p a

proc

ess

to c

olla

bora

te w

ith o

ther

fede

ral g

over

nmen

t age

ncie

s an

d pr

ivate

sec

tor r

egar

ding

effe

ctive

hum

an c

apita

l stra

tegi

es

and

to b

ench

mar

k be

st p

ract

ices

and

less

ons

lear

ned.

Acco

unta

bility

Sys

tem

De

velo

p a

form

al a

ccou

ntab

ility

syst

em th

at s

tate

s th

e bu

reau

’s ac

coun

tabi

lity p

olicy

, key

resp

onsib

ilitie

s, o

utco

mes

and

mea

sure

s,

mile

ston

es a

nd re

sults

and

mee

ts O

PM’s

requ

irem

ents

for a

sou

nd h

uman

cap

ital a

ccou

ntab

ility

syst

em th

at m

easu

res

effe

ctive

ness

in

mee

ting

the

requ

irem

ents

.

De

velo

p an

app

raisa

l sys

tem

for s

enio

r exe

cutiv

es th

at h

as a

ppro

pria

te m

easu

res

or in

dica

tors

of e

mpl

oyee

and

or c

usto

mer

feed

back

.

De

velo

p a

proc

ess

that

hol

ds m

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ers

and

hum

an re

sour

ces

offic

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acco

unta

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nt a

nd e

ffect

ive h

uman

reso

urce

s m

anag

emen

t in s

uppo

rt of

the

bure

au’s

miss

ion.


27

Section 3: Consumer Response

3.1 Scope of Audit

In this section, we establish scope boundaries for our audit of CFPB’s performance in the area of Consumer Response. Consumer Response’s mandate is to facilitate the centralized collection of, monitoring of, and response to complaints regarding consumer financial products or services; and to interpret and utilize consumer complaints and other feedback both to improve its own operations and to contribute to the eventual improvement of consumer financial products/services. This mandate and the operations required to address it align closely with customer experience management and customer loyalty disciplines in a wide variety of business-to-business (B2B) and business-to-consumer (B2C) industries. In order to evaluate the CFPB’s performance with respect to Consumer Response, we employed an overall framework informed by both general customer experience management best practices and a behavioral model originally developed by the American Customer Satisfaction Index (ACSI) to provide insight into consumer satisfaction with local and federal government services (i.e., the American Consumer Satisfaction IndexTM Government Model)1. The resulting framework, diagrammed in the figure below, contains three main components—experience preparation, experience execution, and desired stakeholder behaviors. Our premise is that stakeholder2 behaviors and reactions with regard to a given entity (e.g., CFPB Consumer Response) are a direct byproduct of how well that entity: (1) understands stakeholder needs and expectations; (2) defines how it will address stakeholder needs and expectations; and (3) executes/adjusts its operational plans based on stakeholder feedback. Specifically, experience preparation may include key activities like:

defining and segmenting key operational stakeholders – consumers and/or others gathering insight from stakeholders on their needs and expectations relative to Consumer

Response activity – essentially, the “ideal experience” they desire crafting a high-level strategy to address stakeholder needs and deliver the desired stakeholder

experience, given any other pre-existing operational metrics or constraints (legal, operational or financial)

1 The American Customer Satisfaction Index, (ACSI) is a private company originally founded in 1994 through the partnership of the University of Michigan/Ross School of Business, the American Society for Quality, and Claes Fornell International. The ACSI interviews about 80,000 Americans annually and asks about their satisfaction with the goods and services they have consumed. Respondents address a wide range of business-to-consumer products and services, including durable goods, services, non-durable goods, local government services, federal government services, etc. Results from data collection and analyses are released to the public throughout each calendar year and utilized to inform and test behavioral models that connect product/service provider actions with desired customer outcomes (e.g., satisfaction, willingness to purchase and/or recommend). The American Consumer Satisfaction Index TM Government Model is one of these models.

2 The term “stakeholders” is used here to refer to consumers, Congress, covered persons/entities as defined in Dodd-Frank, and other federal agencies


28

defining clear roles, responsibility and accountability for ideal experience delivery within Consumer Response and between Consumer Response personnel and other relevant departments or agencies

Experience execution is all about following through: embedding key elements of ideal experience strategy and regular stakeholder feedback into daily operating processes, policies, and systems. Execution begins with implementing key business processes that reflect stakeholder needs; within Consumer Response, these would include intake, tracking/resolution and analysis/reporting processes. Beyond this, successful experience execution may be dependent on multiple related factors, including things like:

providing clarity to stakeholders around key business processes [Process Information] administering communication channels for stakeholders that reflect how stakeholders want to

interact with Consumer Response, available when stakeholders want them [Customer Service, Website]

instituting process and outcome measurement capabilities and using insight from measurement for the purposes of continuous improvement [Outcomes Measurement & Continuous Improvement]

Consumer Response Evaluation Framework

In the case of CFPB Consumer Response, resulting desired stakeholder behaviors may include things like:

stakeholder agreement that the bureau is delivering on its legislative mandate, stakeholder willingness to recommend existing CFPB Consumer Response processes to

others to resolve relevant disputes or address relevant inquiries,


29

stakeholder confidence in CFPB Consumer Response processes and personnel, or stakeholder cooperation, co-development and/or compliance with CFPB policies, processes

and guidance The CFPB’s Consumer Response function is new enough that it may not be possible to assess the degree to which the bureau is achieving these desired stakeholder behaviors today. However, we can examine its experience preparation and experience execution activities to date—as well as related systems, processes and tools—to gain insight on how well Consumer Response may achieve desired stakeholder behaviors in the future. For more information on each of the experience preparation and execution activity areas in the graphic above, see our evaluation criteria in Section 3.2. Our audit focuses predominantly on the CFPB credit card complaint system with the understanding that many of the tools, practices and roles being put into place to execute this system are foundational to future Consumer Response activities. That said, it is not expected that the activities and plans listed above will fully address all aspects of the performance framework listed in Section 3.1. Our efforts have disproportionately focused on those areas of experience preparation and execution that were fully operational as of August 31, 2011. In cases where the CFPB has already demonstrated progress or documented future-state plans, those activities are mapped to the corresponding area of our evaluation framework, and performance is evaluated relative to our proposed criteria (see Section 3.2). For those framework areas where the bureau has not yet demonstrated progress or has limited performance data, this performance audit provides general recommendations regarding: (1) best practices with respect to performance in these dimensions; and (2) future audits of performance in these areas. As an example, a detailed quantitative and qualitative analysis of call center operational efficiency is out of scope for this audit, although it represents a prospective focus area for future audits of Consumer Response performance given CFPB reliance on this as a complaint/inquiry intake channel.




The bullets below describe specific provisions of the Dodd-Frank Act that establish requirements and/or evaluation criteria in the area of Consumer Response (Sections 1013(b)(3) and 1034).

Section 1013(b)(3)(A) of the Dodd-Frank Act requires the CFPB to establish “a single, toll free telephone number, a website, and a database or utilizing an existing database to facilitate the centralized collection of, monitoring of, and response to consumer complaints regarding consumer financial products or services.”


30

Section 1013(b)(3)(A) of the Dodd-Frank Act requires the CFPB to coordinate with the FTC and other federal agencies to route complaints to those agencies, where appropriate, and route complaints “[t]o the extent practicable” to states that meet certain requirements.

Section 1013(b)(3)(C) of the Dodd-Frank Act requires the CFPB to report to Congress annually on complaint numbers, types and, where applicable, resolution. In addition, Section 1016(b)(2) calls for semiannual reports that include “an analysis of complaints about consumer financial products and services that the Bureau has received and collected in its central database on complaints during the preceding year.”

Section 1013(b)(3)(D) of the Dodd-Frank Act requires the CFPB to share data with prudential regulators, the Federal Trade Commission, other Federal agencies, and State agencies, to “facilitate preparation of [annual Congressional] reports . . . , supervision and enforcement activities, and monitoring of the market for consumer financial products and services.”

Section 1034(a) of the Dodd-Frank Act requires the CFPB to establish (in consultation with the appropriate federal regulators) “reasonable procedures to provide a timely response to consumers, in writing, where appropriate” to complaints and inquiries that include the regulators’ steps in response; responses received from the covered person; and any follow-up regulator actions.

Section 1013(e)(1)(B) of the Dodd-Frank Act requires the CFPB to monitor complaints by servicemembers and their families, and responses thereto.


In order to assess achievement of organizational goals, we evaluated the progress that CFPB has made towards measurable goals that are documented in CFPB planning artifacts. The bullets below describe the specific organizational goals that are included in our analysis. These goals were derived from Consumer Response-provided documentation including new hire training materials, contact center statement of work and related service level agreement materials and product rollout schedules. Goals by major operational area include:

Overall Standup o Meet documented milestone timing in Contact Center Phase I & II milestone calendar o Meet documented milestone timing for overall Consumer Response project plan

(across all major initiatives, beyond just the CFPB contact center)

Intake of Consumer Contacts – Contact Center o 100% compliance with contact center service level agreement

Routing of (Credit Card) Complaints

o Routing of complaints to banks, regulators within 48 hours of intake

Routing of Other Contacts, Inquiries


31

o Immediate response to Tier 1 through 2 phone inquiries o Absolute maximum elapsed time of 7 days between warm transfer of Tier 3 phone

inquiry and resolution (ideal within 24 hours) o Acknowledgement of written inquiry within 48 hours of receipt o Response to written inquiry by Consumer Response within 30 days of receipt

Management and Tracking of Complaints and Resolution (Bank/Regulator Resolution)

o Response from bank/regulator to consumer within 10 days of initial complaint o Response from bank/regulator during 1st, 2nd or 3rd tier CFPB investigations (note:

target in this case is not yet established as of September 27, 2011)

Management and Tracking of Complaints and Resolution (CFPB Investigations) o Completion of 1st, 2nd or 3rd tier investigations within 20 days of investigation start

Quality Assurance and Analysis/Reporting of Contact Data

o To be determined, and therefore generally excluded from this “achievement of organizational goals” analysis; this element of Consumer Response operations is still clearly in standup mode (e.g., hiring analysts, investigation staff is in process as of September 27, 2011).


In order to assess alignment with performance standards and best practices, we evaluated the progress that CFPB has made relative to an overall performance framework that is informed by both general customer experience management best practices and the American Consumer Satisfaction IndexTM Government Model), as described in section 3.1. They include:

Planning Standards o Evidence of segmenting stakeholder base and soliciting information on desired

stakeholder experience (stakeholder experience definition) o Clear mapping between stakeholder experience and department functionality o Documentation that includes milestones, timing, critical dependencies

Governance Standards

o Clear roles/responsibilities/accountability within CR o Clear roles/responsibilities/accountability between CR and related agencies, covered

persons o Documented/clear/accessible internal operating standards and related targets

Measurement & Actioning Standards (Process)

o Ease and timeliness of intake processes o Ease and timeliness of resolution processes (credit cards) o Ease and timeliness of reporting processes (credit cards) o Alignment of channels/touch points to key consumer segments

Measurement & Actioning Standards (Information)


32

o Accessibility and transparency of complaint resolution process and outcomes (from stakeholder point of view)

Measurement & Actioning Standards (Customer Service) o Courtesy and professionalism of live touch points (800 # call center/IVR and live chat)

Measurement & Actioning Standards (Website)

o Ease/utility of CR website – consumer complaint intake form o Ease/utility of CR website – other current supporting functionality (e.g., Tell Your

Story)

Measurement & Actioning Standards (Outcomes) o Performance versus internal standards/metrics (e.g., time to resolution) o Performance versus stakeholder expectations (beyond basic compliance) o Linkage between measurement and continuous process improvement o Quality of reporting to inform future CFPB scope, reduce complaints over time




Table 7 presents our assessment of the CFPB’s compliance with legal requirements. Each row in this table corresponds to a specific legal requirement. For each requirement, we describe the progress that the bureau has demonstrated to date, along with recommendations for future action. The bullets below highlight our key findings and recommendations

CFPB’s Consumer Response function has complied with all relevant legal requirements. CFPB should use the credit card complaint standup approach – and learnings derived from its initial implementation – as a template of sorts as Consumer Response continues to expand its scope beyond the credit complaint area into mortgages and other financial products/services.


Table 8 presents our detailed assessment of the CFPB’s achievement of organizational goals. Each row in this table corresponds to a specific organizational goal. For each goal, we describe the progress that the bureau has demonstrated to date (findings), along with recommendations for future action. The bullets below highlight our key findings and recommendations.

Consumer Response is in compliance with its own internal organizational performance targets in those areas where: (1) targets have been documented; and (2) CFPB has officially begun holding itself and others to performance targets that have been set thus far.


33

CFPB should finalize all remaining targets tied to major operational metrics – and begin

enforcing targets as soon as possible. As of this report, Consumer Response has yet to establish and/or enforce final targets for operational metrics like maximum bank/regulator response time during CFPB investigations, or standards around frequency and scope of periodic quality assurance analysis and reporting (outside the intake/call center area). The sooner CFPB establishes targets for these critical activity areas, the sooner it can begin tracking performance associated with the full scope of its mandate, and the better prepared it will be to provide periodic reporting and analysis to other stakeholders. From a practicality perspective, committing to and enforcing targets quickly also helps avoid generating an unworkable backlog of complaints and/or investigations as consumer contact volume invariably increases. Enforcing existing targets should also increase the speed with which key external contractors (e.g., contact center) build a sense of accountability and responsiveness to improve average customer service representative skills and consistency of service delivery.

CFPB should consider adding consumer resolution dispute rate to its featured short-list of major operational metrics. Including this metric (i.e., % of “resolved” complaints that consumers subsequently dispute) can increase leadership visibility into what affected consumers may perceive as the effectiveness of current Consumer Response processes, and help uncover themes and/or emerging issues in individual bank investigation performance. Today, all metrics and targets listed in section 3.2.2. of this document focus exclusively on efficiency (timeliness).

CFPB should organize milestone information across Consumer Response. We also suggest that Consumer Response establish a master milestone calendar across all its major projects and initiatives to track progress and surface critical interdependencies. Documentation provided by CFPB during this audit contains examples of master milestone tracking up through CFPB’s July 21 launch date, but only evidence of milestone development and tracking on an individual project and/or functional area basis thereafter. Consolidating and tracking milestones across projects today will continue to help the department manage its ongoing standup activities and communicate progress effectively to internal and external stakeholders.

CFPB should establish a single Consumer Response master dashboard to track and communicate actual performance against targets. This master dashboard may contain different tabs/views, covering either department-wide (standup) goals or goals specific to each financial product CFPB eventually addresses. Generally, however, the goal should be to minimize differences across dashboard views to ensure appropriate focus on the core elements of Consumer Response’s mission, and to facilitate easy comprehension and interpretation of performance data. We would, for example, expect the operational area categories from section 3.2.2 of this document (e.g., overall standup, intake of consumer contacts, routing of complaints) to remain fixed, across any covered/relevant financial product. Internal metrics from section 3.2.2 (e.g., compliance with contact center service level agreement) would also change very little across products, emphasizing process timeliness and consumer satisfaction data once CFPB emerges from its initial standup phase. Individual targets may vary more


34

broadly, reflecting process nuances associated with complaint resolution and investigation for different product types.


Table 9, Table 10 and Table 11 present our assessment of the CFPB’s alignment with performance standards and best practices. Each row in these tables corresponds to a specific performance criterion/success factor within our larger Consumer Response evaluation framework (see section 3.1). For each success factor, we provide the following information: (1) a rating of CFPB’s performance to date, using a stoplight scale (i.e., Red, Yellow or Green); (2) a summary of demonstrated performance; (3) the priority of future progress in this area, based on the importance of the performance area for a start-up organization; and (4) recommendations for future action. Two overarching themes exist across our evaluation, namely:

1. Consumer Response has clearly leveraged stakeholder feedback to help frame its initial organizational design. Recall that understanding stakeholder needs/expectations and using this understanding to inform operations is a critical driver of desired stakeholder behavior (e.g., adoption/usage, cooperation, recommendation).

2. Consumer Response currently demonstrates operational rigor to deliver the desired stakeholder experience from an intake process perspective – particularly when it comes to process documentation and training associated with its contact center.

Going forward, the challenge for Consumer Response is to:

Maximize consistency in its contact center intake technician and specialist performance; Develop the same process and performance rigor for currently developing operational areas

outside of intake, particularly in the areas of CFPB complaint review and investigation; Balance ongoing operational improvement in the credit card area while maintaining

momentum in the expansion of other covered financial products and services, and Continue to establish and use formal stakeholder feedback channels, both for continuous

improvement with its credit card complaint processes and to inform design as it moves beyond this area

The bullets below highlight our other key findings and recommendations not yet referenced in the preceding discussion within this document’s Findings and Recommendations section. Nearest-Term Opportunities for Improvement (High Priority)

CFPB should implement an OMB-approved consumer satisfaction survey as a basic means to begin systematically collecting feedback directly from those who are experiencing CFPB’s operations today.

CFPB should leverage the feedback it is already collecting. As one example, the bureau

should continue to establish operational goals and processes around mining contacts currently stored in Consumer Response’s contact management system as “feedback.”


35

CFPB should complete the standup of key remaining operational enablers. This includes launching Consumer Response’s consumer-facing knowledge base, completing implementation of its complex case management system, and ramping up to at least minimum analyst staffing levels required to support quality assurance reviews for CFPB investigations and to develop/execute a master performance dashboard (as referenced on page 31). It also includes accelerating the in-process standup of contact center CSR monitoring and coaching/training to improve consistency of CSR performance.

Mid-Term Opportunities for Improvement (Medium Priority)

CFPB should draft a more formal “stakeholder feedback platform” plan, which would address topics such as: (1) how feedback will be collected and used to improve operations; and (2) how feedback will be collected and used to improve financial products and services. CFPB should whiteboard current feedback mechanisms by key operational areas, (e.g., intake, routing, tracking/resolution, analysis) channels (e.g., website, toll-free number) and stakeholder type (e.g., prudential regulators, covered persons, consumer advocacy groups, mass consumer audiences). In order to test the relevance and value of these feedback mechanisms, CFPB should consider who will use the feedback from each data stream, how the feedback will be used, and what the bureau [or other relevant stakeholders] will do differently as a result of this feedback.

CFPB should look for gaps in the formality, frequency, coverage and intent/functionality of its existing feedback mechanisms. The ideal platform should include a mix of quick/near-time/operational feedback and broad/infrequent/strategic feedback. CFPB should bound the volume of feedback mechanisms in part based on its bandwidth to analyze the resulting data. Feedback channels can also offer the opportunity to understand CFPB performance/value from the view of the stakeholder and act as a form of outreach to collaborate on solution development or continuous improvement. One vehicle for this type of collaboration is a stakeholder advisory board/community (or multiple versions of the same). Tips to maximize the impact of stakeholder advisory boards include:

o Enact rotating membership, limiting stakeholder participants to 18 to 24-month terms maximum

o Focus formal board meetings/discussions on a single objective and related discussion topic whenever possible, and prepare board members with advance materials to provide context

o Use board member feedback to inform future topics and to shape the frequency of interaction – but generally, expect quarterly interaction at most

o Use a third-party facilitator to moderate meetings, allowing Consumer Response staff to contribute and listen actively. (Note: “third-party” can mean a CFPB staff member outside of Consumer Response. Focus group facilitation experience is a plus for any potential moderator.)

o Explore opportunities to facilitate interaction between board members outside Consumer Response – often, board members see the opportunity to build relationships with other members as part of what makes membership worthwhile


36

CFPB should communicate progress to key stakeholders. Specifically, the bureau should consider employing the concept of an “annual CFPB Consumer Response scorecard” to summarize key performance metrics, results, feedback themes and implications and/or anticipated improvement initiatives. A scorecard of this type, distributed to Consumer Response staff along with internal and external stakeholders, improves accountability, maximizes clarity of operations and reinforces CFPB’s commitment to its mandate.

CFPB should complement its existing position description and procedural documentation with RACI. A 1 or 2-page RACI document should map out who is responsible, accountable, who should be consulted and who should be informed with regard to major activities within Consumer Response. A RACI document provides a single, easily digestible artifact of roles and responsibilities with and across CFPB and related agencies/covered persons. This can be a valuable communications tool given how dependent Consumer Response operations are on close coordination with other CFPB offices and external stakeholders.

CFPB should institute a “universal contact code” policy for all contacts, assuming one does not currently exist. The bureau should mandate the use of this policy on all communications/status updates associated with individual complaints or related investigations – particularly on any documents that may exist outside of Consumer Response’s contact management system. The code can enable easy tracking of information as it flows between Consumer Response, regulators and covered persons, and should tie to relevant record ID codes within the contact management system.

Longer-Term Opportunities for Improvement (Low Priority)

CFPB should complete the conceptual development of a feedback platform, secure approvals as needed and begin to implement. Note that “approvals” in this case means both completing relevant compliance activity (e.g., Paperwork Reduction Act-mandated work), but also securing buy-in from other CFPB offices or other key stakeholders to utilize insight generated from the feedback that Consumer Response collects and analyzes.

CFPB should enhance process transparency to consumers and other stakeholders. One way to accomplish this goal is to leverage stakeholder feedback, in order to enhance the clarity of CFPB processes and performance expectations in ways that are relevant to each major stakeholder group. For consumers, one relatively quick “win” in this area would be to build notification capability to alert complainants as investigations move through CFPB’s tiers. For other CFPB offices, this could mean exploring the feasibility of replicating the current knowledge-sharing model in place with the Office of Servicemember Affairs (OSA), thereby improving the ability of other departments to contribute to Consumer Response’s investigation, tracking and analysis efforts.

CFPB should consider enhancing future intake specialist, investigator and QA/QC staff capabilities via certification program(s). It is our understanding that CFPB is in the process of developing more formal performance management systems as of this report date. Intake specialists, investigators and QA/QC staff are three CFPB operational roles that may benefit


37

from the establishment of a more formal certification program as part of this work. Setting and supporting certification expectations helps enforce consistent delivery of the desired stakeholder experience when it comes to complaint tracking, resolution and analysis – in much the same way as the formal customer service representative evaluation and training programs that Consumer Response is implementing now is designed to reinforce consistent quality among its contact center staff.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

38

Tab

le 7

: C

omp

lian

ce w

ith

Leg

al R

equ

irem

ents

Lega

l Req

uire

men

t De

mon

stra

ted

Perfo

rman

ce

Find

ing

/ Rec

omm

enda

tion

Cent

raliz

e th

e in

take

for c

onsu

mer

com

plai

nts

abou

t con

sum

er fin

ancia

l pr

oduc

ts a

nd s

ervic

es.

Esta

blish

“a s

ingl

e, to

ll-fre

e te

leph

one

num

ber,

a we

bsite

, and

a d

atab

ase

or u

tilizin

g an

exis

ting

data

base

to fa

cilita

te th

e ce

ntra

lized

col

lect

ion

of, m

onito

ring

of, a

nd re

spon

se to

con

sum

er

com

plai

nts

rega

rdin

g co

nsum

er fin

ancia

l pro

duct

s or

ser

vices

.” S

ectio

n 10

13(b

)(3)(A

).

• CF

PB w

ebsit

e •

Cont

act c

ente

r ope

ratio

nal

• Cr

itical

dep

ende

ncy

supp

ortin

g sy

stem

s (i.

e., C

RM)

oper

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t bas

e le

vel fu

nctio

nality

Mul

tiple

com

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proo

f poi

nts

exta

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day.

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e co

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aint

s. C

FPB

mus

t coo

rdin

ate

with

the

FTC

and

othe

r fe

dera

l age

ncie

s to

rout

e co

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aint

s to

thos

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s, w

here

ap

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s “[t

]o th

e ex

tent

pra

ctica

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to s

tate

s th

at m

eet c

erta

in re

quire

men

ts.

Sect

ion

1013

(b)(3

)(A),

(B).

• Ro

utin

g po

lices

exe

cute

d via

con

tact

cen

ter a

nd

docu

men

ted

in C

onsu

mer

Res

pons

e St

anda

rd

Ope

ratin

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oced

ures

– fo

cuse

d on

pru

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ial

regu

lato

rs, c

over

ed p

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No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Re

port

to C

ongr

ess

annu

ally

on c

ompl

aint

num

bers

, typ

es

and,

whe

re a

pplic

able

, res

olut

ion.

Sec

tion

1013

(b)(3

)(C).

Se

mia

nnua

l rep

orts

will

requ

ire “a

n an

alys

is of

com

plai

nts

abou

t con

sum

er fin

ancia

l pro

duct

s an

d se

rvice

s th

at th

e CF

PB h

as re

ceive

d an

d co

llect

ed in

its c

entra

l dat

abas

e on

co

mpl

aint

s du

ring

the

prec

edin

g ye

ar.”

Sec

tion

1016

(b),

(c)(4

)

• No

repo

rting

due

as

of a

udit d

ate.

No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce e

lem

ent

Shar

e da

ta w

ith p

rude

ntia

l reg

ulat

ors,

the

Fede

ral T

rade

Com

miss

ion,

ot

her F

eder

al a

genc

ies,

and

Sta

te a

genc

ies,

to “f

acilit

ate

prep

arat

ion

of

[ann

ual C

ongr

essio

nal] r

epor

ts .

. . ,

supe

rvisi

on a

nd e

nfor

cem

ent

activ

ities,

and

mon

itorin

g of

the

mar

ket f

or c

onsu

mer

finan

cial p

rodu

cts

and

serv

ices.

” Se

ctio

n 10

13(b

)(3)(D

).

• No

repo

rting

due

as

of a

udit d

ate.

No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce e

lem

ent

Wor

k wi

th o

ther

regu

lato

rs to

est

ablis

h tim

ely

resp

onse

pro

cedu

res.

CF

PB s

hall e

stab

lish

(in c

onsu

ltatio

n wi

th th

e ap

prop

riate

fede

ral

regu

lato

rs) “

reas

onab

le p

roce

dure

s to

pro

vide

a tim

ely

resp

onse

to

cons

umer

s, in

writ

ing,

whe

re a

ppro

pria

te” t

o co

mpl

aint

s an

d in

quirie

s th

at in

clude

the

regu

lato

rs’ s

teps

in re

spon

se; r

espo

nses

rece

ived

from

th

e co

vere

d pe

rson

; and

any

follo

w-up

regu

lato

r act

ions

. Se

ctio

n 10

34(a

).

• Ro

utin

g po

lices

and

inve

stig

atio

n ex

pect

atio

ns

docu

men

ted

in C

onsu

mer

Res

pons

e St

anda

rd

Ope

ratin

g pr

oced

ures

Proc

esse

s wi

ll con

tinue

to c

hang

e ov

er n

ear-t

erm

as

CFP

B ite

rate

s wi

th re

gula

tors

and

cov

ered

pe

rson

s. E

xam

ple:

ban

k po

rtal a

djus

tmen

ts.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

39

Lega

l Req

uire

men

t De

mon

stra

ted

Perfo

rman

ce

Find

ing

/ Rec

omm

enda

tion

Mon

itor c

ompl

aint

s by

ser

vicem

embe

rs a

nd th

eir f

amilie

s, a

nd

resp

onse

s th

eret

o. S

ectio

n 10

13(e

)(1)(B

).

Co

ntac

t cen

ter p

aper

, web

, and

tele

phon

e co

mpl

aint

inta

ke m

etho

ds a

ll inc

lude

que

stio

ns to

id

entify

ser

vicem

embe

rs a

nd d

epen

dent

s of

se

rvice

mem

bers

as

well a

s br

anch

, ran

k, a

nd

stat

us.

Co

nsum

er R

espo

nse

perio

dica

lly s

hare

s ex

ports

of

serv

icem

embe

r com

plai

nts

with

OSA

.

OSA

's Co

nsum

er R

espo

nse

Spec

ialis

t atte

nded

Co

nsum

er R

espo

nse's

regu

lato

ry a

nd C

RM s

yste

m

train

ing

and

has

acce

ss to

the

CRM

sys

tem

, whi

ch

inclu

des

the

abilit

y to

que

ry b

y se

rvice

mem

ber.

• Di

rect

ion/

links

to V

A ho

me

loan

web

site

to a

cces

s sp

ecia

lized

ser

vices

out

side

curre

nt C

FPB

scop

e

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

40

Tab

le 8

: A

chie

vem

ent

of O

rgan

izat

ion

al G

oals

Ope

ratio

nal A

rea

Key

Inte

rnal

Met

ric/S

tand

ard

Targ

et W

hen

Fully

O

pera

tiona

l Ac

tual

To

Date

Fi

ndin

g / R

ecom

men

datio

n

Ove

rall S

tand

up

Cont

act C

ente

r Pha

se I

& II

mile

ston

e ca

lend

ar

Cons

umer

Res

pons

e Pr

ojec

t Pla

n

Mee

t doc

umen

ted

mile

ston

e tim

ing

Mee

t doc

umen

ted

mile

ston

e tim

ing

Phas

e I –

95%

don

e

Phas

e II

– 75

% d

one

Not y

et o

fficia

lly m

easu

red

Cons

umer

-facin

g FA

Q/k

nowl

edge

bas

e no

t onl

ine

Adva

nced

/com

plex

cas

e m

anag

emen

t sy

stem

not

com

plet

ely

in p

lace

Mas

ter p

roje

ct te

am lis

t and

mas

ter

cale

ndar

lead

ing

to la

unch

, bu

t no

ongo

ing

mas

ter m

ilest

one

cale

ndar

and

re

late

d tra

ckin

g ac

ross

team

s?

Inta

ke o

f Con

sum

er C

onta

cts

– Co

ntac

t Cen

ter

Cont

act C

ente

r Ser

vice

Leve

l Agr

eem

ent

100%

com

plia

nce

No

t yet

offic

ially

mea

sure

d SL

A in

revis

ion;

per

con

tract

or

agre

emen

t, do

es n

ot g

o in

to e

ffect

unt

il 90

day

s af

ter l

aunc

h da

te (7

/21)

.

That

sai

d, c

urre

nt C

RM d

ashb

oard

tra

ckin

g of

cal

l cen

ter s

ervic

e le

vels

all

“gre

en” f

or w

/o 9

/3/1

1

Rout

ing

of [C

redi

t Car

d]

Com

plai

nts

Com

plai

nt ro

utin

g to

ban

ks, r

egul

ator

s

With

in 4

8 ho

urs

With

in 4

8 ho

urs

No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce e

lem

ent

Rout

ing

of O

ther

Con

tact

s/

Inqu

iries

Re

spon

se to

pho

ne in

quiry

– T

ier 1

or 2

Resp

onse

to p

hone

inqu

iry –

Tie

r 3

Ackn

owle

dgem

ent o

f writ

ten

inqu

iry

Resp

onse

to w

ritte

n in

quiry

by

Cons

umer

Re

spon

se

Imm

edia

te

With

in 7

day

s m

axim

um (2

4 ho

urs

pref

erre

d)

With

in 4

8 ho

urs

With

in 3

0 da

ys

Not y

et o

fficia

lly m

easu

red

Targ

et o

f 85%

of p

hone

inqu

iries

addr

esse

d wi

thou

t tra

nsfe

r to

man

ager

or

CFP

B –

at 8

5.6%

w/o

9/3

CRM

das

hboa

rd e

xam

ples

sha

red

as o

f 9/

16 fo

cus

on v

olum

e vs

. “tim

elin

ess

of

resp

onse

”

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

41

Ope

ratio

nal A

rea

Key

Inte

rnal

Met

ric/S

tand

ard

Targ

et W

hen

Fully

O

pera

tiona

l Ac

tual

To

Date

Fi

ndin

g / R

ecom

men

datio

n

Mgt

./ Tr

ackin

g of

Com

plai

nts

& Re

solu

tion

Bank

/ Reg

ulat

or

Resp

onse

from

ban

k/re

gula

tor t

o co

nsum

er –

in

itial c

ompl

aint

Resp

onse

from

ban

k/re

gula

tor –

inqu

iries

tied

to

1st,

2nd,

3rd

tier i

nves

tigat

ion(

s)

With

in 1

0 da

ys

Not y

et e

stab

lishe

d

Not y

et o

fficia

lly m

easu

red

Not y

et o

fficia

lly m

easu

red

Not y

et h

oldi

ng b

anks

to 1

0-da

y ta

rget

.

No fo

rmal

targ

ets

set y

et.

Will

need

to s

et

clear

exp

ecta

tions

to m

eet t

arge

t for

tota

l el

apse

d in

vest

igat

ion

time

(see

nex

t row

).

CFPB

Rev

iew/

Inve

stig

atio

n

Elap

sed

time

– 1s

t, 2n

d, 3

rd tie

r inv

estig

atio

n W

ithin

20

days

of

inve

stig

atio

n st

art

Not y

et o

fficia

lly m

easu

red

Targ

et p

er n

ew h

ire tr

aini

ng.

CRM

func

tiona

lity th

at w

ill al

low

for e

laps

ed

time

track

ing

still

in d

evel

opm

ent.

QA

and

Ana

lysis/

Rep

ortin

g of

Co

ntac

t Dat

a

Still

in s

tand

up m

ode:

hirin

g an

alys

ts,

inve

stig

atio

n Q

A st

aff

Not y

et e

stab

lishe

d No

t yet

offic

ially

mea

sure

d Ca

ll cen

ter Q

A/Q

C in

frast

ruct

ure

well

deve

lope

d, a

lthou

gh S

LA m

onito

ring

and

anal

ysis

is ju

st b

egin

ning

.

Ope

n ar

ea is

inve

stig

atio

n an

alys

is an

d tra

ckin

g; e

xpec

t thi

s to

be

deve

lope

d in

pa

ralle

l with

cur

rent

CRM

/cas

e m

anag

emen

t sys

tem

dev

elop

men

t.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

42

Tab

le 9

: A

lign

men

t w

ith

Per

form

ance

Sta

nd

ard

s (P

lan

nin

g)

Fact

or

Scor

e Su

mm

ary

of P

erfo

rman

ce

Prio

rity

Find

ing

/ Rec

omm

enda

tion

Evid

ence

of

segm

entin

g st

akeh

olde

r bas

e an

d so

licitin

g in

form

atio

n on

des

ired

stak

ehol

der

expe

rienc

e (s

take

hold

er

expe

rienc

e de

finitio

n)

Mul

tiple

acc

ompl

ishm

ents

/pro

of p

oint

s, b

eyon

d th

ose

man

date

d (i.

e.,

SORN

pub

lic c

omm

enta

ry) i

nclu

ding

:

Co

nsum

er p

rimar

y re

sear

ch (I

DEO

)

In

vest

igat

ions

into

pee

r gro

up a

ctivi

ties

and

best

pra

ctice

s

Le

vera

ging

sec

onda

ry d

ata

(e.g

., IR

S ta

xpay

er p

refe

renc

e st

udy)

/exp

ertis

e

High

Bu

reau

sho

uld

keep

foun

datio

nal w

ork

in m

ind

when

rollin

g ou

t re

mai

ning

pro

duct

func

tiona

lity

Bu

reau

may

wan

t to

inve

st in

sup

plem

enta

l res

earc

h if/w

hen

CFPB

exp

lore

s ad

ditio

nal fu

nctio

nality

tied

to n

iche

cons

umer

se

gmen

ts (e

.g.,

elde

rly)

Clea

r map

ping

be

twee

n de

sired

st

akeh

olde

r ex

perie

nce

and

depa

rtmen

t fu

nctio

nality

Stak

ehol

der r

esea

rch/

inpu

t use

d fo

r web

site

desig

n, m

ulti-

chan

nel

cont

act a

ppro

ach,

and

inte

rnal

ope

ratin

g st

anda

rds/

met

rics

Med

ium

To

max

imize

tran

spar

ency

/cla

rity,

bur

eau

shou

ld c

onsid

er

prod

ucin

g m

appi

ng d

ocum

ent w

ith s

take

hold

er n

ame/

type

, key

su

gges

tion(

s), e

xistin

g re

late

d fu

nctio

nality

and

pla

nned

fu

nctio

nality

with

exp

ecte

d du

e da

tes.

o

Here

’s wh

at w

e he

ard

o

Here

’s wh

at w

e’ve

don

e

o

Here

’s wh

y

Docu

men

tatio

n th

at

inclu

des

mile

ston

es,

timin

g, c

ritica

l de

pend

encie

s

Ve

ry d

etai

led

docu

men

tatio

n ar

ound

con

tact

cen

ter i

tsel

f, bu

t hav

e ye

t to

see

over

arch

ing

Cons

umer

Res

pons

e fu

nctio

n m

aste

r pr

ojec

t pla

n –

in o

ne p

lace

/doc

umen

t

Im

porta

nt to

isol

ate

critic

al d

epen

denc

ies

and

cont

inge

ncy

plan

s

High

Bu

reau

sho

uld

crea

te s

ingl

e m

aste

r pro

ject

pla

n/ca

lend

ar if

it do

es n

ot e

xist t

oday

Bu

reau

sho

uld

clear

ly iso

late

crit

ical d

epen

denc

ies

asso

ciate

d wi

th s

aid

cale

ndar

/pla

n

Bu

reau

sho

uld

leve

rage

any

upc

omin

g st

rate

gic

plan

ning

/bud

getin

g ac

tivity

to b

olst

er p

lan

docu

men

tatio

n

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

43

Tab

le 1

0: A

lign

men

t w

ith

Per

form

ance

Sta

nd

ard

s (G

over

nan

ce)

Fact

or

Scor

e Su

mm

ary

of P

erfo

rman

ce

Prio

rity

Find

ing

/ Rec

omm

enda

tion

Clea

r rol

es /

resp

onsib

ilitie

s /

acco

unta

bility

with

in

CR

SO

Ps a

nd in

terv

iews

sug

gest

col

labo

ratio

n, c

omm

unica

tion

and

trans

pare

ncy

of ro

les/

resp

onsib

ilitie

s wi

thin

CR

– al

thou

gh ro

les

cont

inue

to e

volve

and

new

role

s em

erge

.

Ev

iden

ce o

f cle

ar ro

les

and

resp

onsib

ilitie

s wi

thin

CFP

B to

sup

port

CR J

uly

21 la

unch

dat

e (C

R St

eerin

g Co

mm

ittee)

.

SO

P sh

ows

evid

ence

of r

ole

expe

ctat

ions

with

rega

rd to

con

sum

er

cont

acts

, but

cla

rifyin

g an

d fo

rmal

izing

role

s –

in p

artic

ular

, via

ho

ldin

g ag

encie

s an

d co

vere

d pe

rson

s ac

coun

tabl

e fo

r the

m –

is a

wo

rk in

pro

gres

s

High

Bu

reau

sho

uld

inclu

de p

roce

ss m

easu

res

and

targ

ets

asso

ciate

d wi

th in

divid

ual r

oles

in p

ositio

n de

scrip

tions

/ pe

rform

ance

man

agem

ent e

xpec

tatio

ns; t

ie to

re

ward

s/re

cogn

ition

Clea

r rol

es /

resp

onsib

ilitie

s /

acco

unta

bility

be

twee

n CR

and

re

late

d ag

encie

s,

cove

red

pers

ons

Med

ium

Bu

reau

may

con

sider

form

al d

ivisio

n of

labo

r/RAC

I doc

umen

t as

syst

ems

norm

alize

– a

s sin

gle

go-to

arti

fact

of r

oles

, re

spon

sibilit

ies

with

in a

nd a

cros

s en

tities

for m

ajor

func

tions

If

CFPB

cho

oses

to c

reat

e a

form

al d

ivisio

n of

labo

r/RAC

I do

cum

ent,

it sho

uld

crea

te th

is co

llabo

rativ

ely

with

sta

keho

lder

s fo

r max

imum

impa

ct

Docu

men

ted/

clear

/ ac

cess

ible

inte

rnal

op

erat

ing

stan

dard

s an

d re

late

d ta

rget

s

In

tern

al s

tand

ards

and

targ

ets

set f

or m

ost o

pera

tiona

l are

as

Co

ntac

t cen

ter n

ew h

ire e

duca

tion

inclu

des

info

rmat

ion

on ta

rget

s

Ac

cess

ibilit

y an

d co

mm

on u

nder

stan

ding

of t

arge

ts a

cros

s en

tire

CR o

rgan

izatio

n an

d re

leva

nt e

xter

nal s

take

hold

ers

is un

clear

Ag

ain

– a

work

in p

rogr

ess

Med

ium

Bu

reau

sho

uld

expl

ore

linkin

g bo

th ta

rget

and

ratio

nale

with

in

staf

f tra

inin

g fo

r edu

catio

nal p

urpo

ses

Bu

reau

sho

uld

ensu

re th

at re

leva

nt m

etric

def

initio

ns a

re e

asily

ac

cess

ible

with

in a

ny fu

ture

das

hboa

rd re

porti

ng C

R ad

opts

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

44

Tab

le 1

1: A

lign

men

t w

ith

Per

form

ance

Sta

nd

ard

s (M

easu

rem

ent

& A

ctio

nin

g)

Fact

or

Scor

e Su

mm

ary

of P

erfo

rman

ce

Prio

rity

Find

ing

/ Rec

omm

enda

tion

PRO

CESS

: Eas

e an

d tim

elin

ess

of

inta

ke p

roce

sses

SO

P do

cum

ent w

ith c

lear

inta

ke p

roce

ss d

ocum

enta

tion

Tr

aini

ng m

odul

es c

ompl

ete

– ju

st o

ne e

xam

ple

of in

-dep

th C

SR

prep

arat

ion

to s

uppo

rt pr

oces

s

Ev

iden

ce o

f add

ress

ing

itera

tive

chan

ge re

ques

ts to

twea

k co

ntac

t ce

nter

SO

P/su

ppor

ting

CRM

High

Bu

reau

sho

uld

mon

itor u

ser c

omm

ents

for n

avig

atio

nal e

ase

past

initia

l inta

ke p

age

– co

nsid

er a

ddin

g to

web

site

func

tiona

lity

Bu

reau

sho

uld

impl

emen

t con

tact

cen

ter c

usto

mer

sat

isfac

tion

surv

ey a

s so

on a

s po

ssib

le

PRO

CESS

: Eas

e an

d tim

elin

ess

of

reso

lutio

n pr

oces

ses

(cre

dit c

ards

)

Ch

alle

nges

exp

erie

nced

in g

ettin

g su

pple

men

tal/fo

llow

up

inve

stig

atio

n da

ta fr

om b

anks

and

oth

er b

ank

porta

l func

tiona

lity

Ca

se m

anag

emen

t sys

tem

func

tiona

lity in

com

plet

e in

CRM

; de

velo

pmen

t wor

k un

derw

ay to

bui

ld o

ut fu

nctio

nality

Te

am-b

ased

inve

stig

atio

ns a

ppro

ach

min

imize

s le

arni

ng c

urve

for

new

staf

f

So

me

anec

dota

l pos

itive

feed

back

sha

red

by in

terv

iewe

es (f

rom

co

nsum

ers)

Med

ium

Bu

reau

sho

uld

impl

emen

t con

tact

cen

ter c

usto

mer

sat

isfac

tion

surv

ey a

s so

on a

s po

ssib

le

Bu

reau

sho

uld

cons

ider

em

ploy

ing

“uni

vers

al c

onta

ct c

ode”

to

enab

le e

asy

track

ing

of c

onta

cts

as in

form

atio

n flo

ws b

ack

and

forth

acr

oss

regu

lato

rs (a

nd to

incr

ease

abi

lity to

leve

rage

al

read

y el

ectro

nica

lly s

tore

d pa

perw

ork/

cont

act d

ata

asso

ciate

d wi

th in

divid

ual r

ecor

ds)

PRO

CESS

: Eas

e an

d tim

elin

ess

of

repo

rting

pro

cess

es

(cre

dit c

ards

)

Fo

rmal

repo

rting

(e.g

., Q

uality

Ass

uran

ce R

evie

ws) n

ot y

et

unde

rway

M

ediu

m

Bu

reau

sho

uld

cont

inue

with

rele

vant

QC

and

data

hire

s to

re

sour

ce m

easu

rem

ent,

insp

ectio

n, re

porti

ng a

nd re

late

d an

alys

is

PRO

CESS

: Al

ignm

ent o

f ch

anne

ls/to

uch

poin

ts to

key

co

nsum

er s

egm

ents

Clea

r con

nect

ion

betw

een

stak

ehol

der r

esea

rch

and

mul

ti-ch

anne

l ap

proa

ch

High

Bure

au s

houl

d co

ntin

ue to

min

e ch

anne

l usa

ge in

form

atio

n to

de

term

ine

whet

her n

eed

to a

djus

t hou

rs o

f ope

ratio

n/ac

cess

for

non-

inte

rnet

-bas

ed c

hann

els

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

45

Fact

or

Scor

e Su

mm

ary

of P

erfo

rman

ce

Prio

rity

Find

ing

/ Rec

omm

enda

tion

INFO

RMAT

ION:

Ac

cess

ibilit

y,

trans

pare

ncy

of

com

plai

nt re

solu

tion

proc

ess

and

outc

omes

- fro

m

stak

ehol

der p

oint

of

view

(PO

V)

No

form

al fe

edba

ck s

yste

ms

in p

lace

toda

y to

gat

her c

onsu

mer

re

actio

ns to

pro

cess

or o

utco

mes

– s

o di

fficul

t to

gaug

e

perfo

rman

ce fr

om s

take

hold

er P

OV

W

hile

exis

ting

inta

ke c

hann

els

allo

w fo

r uns

truct

ured

feed

back

(via

ph

one,

Tel

l You

r Sto

ry),

min

ing

of d

ata

to te

st

acce

ssib

ility/

trans

pare

ncy

is a

work

in p

rogr

ess

Ba

selin

e st

ill be

ing

mea

sure

d fo

r rel

ated

met

rics

like

cons

umer

re

solu

tion

disp

ute

rate

Low

Bu

reau

sho

uld

cont

inue

bui

ldin

g no

tifica

tions

cap

abilit

y/

cons

umer

por

tal a

cces

s to

allo

w fo

r mor

e ro

bust

sta

tus/

track

ing

capa

bility

(i.e

., no

tify c

onsu

mer

as

inve

stig

atio

n m

oves

thro

ugh

tiers

, as

rele

vant

).

CUST

OM

ER

SERV

ICE:

Cou

rtesy

an

d pr

ofes

siona

lism

of

live

touc

h po

ints

(8

00 #

cal

l cen

ter/I

VR

and

live

chat

)

Al

l CSR

s un

derg

o so

ft sk

ills tr

aini

ng to

rein

forc

e pr

ofes

siona

lism

in

addi

tion

to a

bro

ader

trai

ning

pro

gram

on

SOP

Ev

iden

ce o

f usin

g cu

rrent

CSR

feed

back

/cal

l per

form

ance

to

enha

nce

tool

s av

aila

ble

to C

SRs

durin

g co

nsum

er in

tera

ctio

n

Co

ntac

t cen

ter s

ervic

e le

vel a

gree

men

t set

s st

anda

rds

for C

SR

perfo

rman

ce, r

egul

ar s

corin

g/te

stin

g of

con

tact

s, a

nd th

e us

e of

re

late

d fin

ding

s to

impr

ove

train

ing

and

CSR

perfo

rman

ce;

howe

ver,

cont

ract

or n

ot o

fficia

lly h

eld

to S

LA u

ntil N

ovem

ber 1

In

itial o

ppor

tuni

stic

“test

” of li

ve c

hat a

nd 8

00#

show

ed c

ourte

ous,

pr

ofes

siona

l inte

ract

ion

but s

ome

coor

dina

tion

issue

s (i.

e.,

conf

lictin

g in

form

atio

n fro

m C

SR a

nd liv

e ch

at o

pera

tor o

n sa

me

topi

c)

Re

mot

e m

onito

ring

of 2

sam

ple

reco

rded

cal

ls al

so s

howe

d in

cons

isten

cy in

ser

vice

expe

rienc

e de

liver

y –

goin

g “o

ff sc

ript”

vers

us c

urre

nt S

OP,

for e

xam

ple

High

Bu

reau

sho

uld

acce

lera

te s

tand

up o

f cal

l cen

ter Q

C ac

tivity

and

re

late

d co

achi

ng/tr

aini

ng fo

r ind

ividu

al C

SRs

to im

prov

e co

nsist

ency

of c

onsu

mer

con

tact

exp

erie

nce

Bu

reau

sho

uld

expl

ore

pote

ntia

l to a

ccel

erat

e ad

optio

n of

SLA

to

befo

re N

ovem

ber 1

WEB

SITE

: Ea

se/u

tility

of C

R we

bsite

– c

onsu

mer

co

mpl

aint

inta

ke fo

rm

Web

site

Gra

der.c

om -

Web

site

eval

uatio

n to

ol to

eva

luat

e ea

se,

usab

ility

(in lie

u of

spe

cific

cons

umer

feed

back

)

W

ebsit

e G

rade

: 92

out o

f 100

. Rev

iew

repo

rt at

High

Bure

au s

houl

d m

onito

r use

r com

men

ts fo

r nav

igat

iona

l eas

e/ut

ility;

ca

n le

vera

ge lo

w co

st e

xistin

g to

ols

to g

et g

ener

al e

xper

ienc

e fe

edba

ck (e

.g.,

4Q)

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

46

Fact

or

Scor

e Su

mm

ary

of P

erfo

rman

ce

Prio

rity

Find

ing

/ Rec

omm

enda

tion

WEB

SITE

: Ea

se/u

tility

of C

R we

bsite

– o

ther

cu

rrent

sup

porti

ng

func

tiona

lity (e

.g.,

Tell

Your

Sto

ry)

http

://we

bsite

grad

er.c

om/s

ite/w

ww.c

onsu

mer

finan

ce.g

ov

High

Hom

epag

e

Bu

reau

sho

uld

cons

ider

mov

ing

“Bui

ldin

g th

e CF

PB” p

lace

men

t as

func

tiona

lity e

xpan

ds, t

o m

ake

room

for c

lear

cal

ls-to

-act

ion

asso

ciate

d wi

th c

ritica

l com

plai

nt in

take

act

ivity

Bu

reau

sho

uld

cons

ider

redu

cing

heig

ht o

f the

hom

epag

e to

m

inim

ize v

ertic

al s

crol

ling

Sear

ch E

ngin

e O

ptim

izat

ion

Bu

reau

sho

uld

cons

ider

mod

ifyin

g te

xt in

clude

d in

imag

es o

n th

e CF

PB h

omep

age;

imag

es c

anno

t be

read

by

sear

ch e

ngin

es

(Goo

gle,

Yah

oo, B

ing)

ther

efor

e, ra

nk lo

wer i

n se

arch

resu

lts

OUT

COM

ES:

Perfo

rman

ce v

ersu

s in

tern

al

stan

dard

s/m

etric

s (e

.g.,

time

to

reso

lutio

n)

M

any

inte

rnal

sta

ndar

ds n

ot y

et e

stab

lishe

d

Ho

weve

r, fo

r man

y of

thos

e se

t (e.

g., c

ompl

aint

rout

ing

to

bank

s/re

gula

tors

) com

plyin

g wi

th in

tern

al s

tand

ards

M

ediu

m

Bu

reau

sho

uld

cont

inue

impl

emen

tatio

n of

con

tact

cen

ter Q

A pl

an

Bu

reau

sho

uld

get n

on-c

onta

ct c

ente

r ope

ratio

ns to

sam

e le

vel

of m

etric

s vis

ibilit

y as

cal

l cen

ter:

This

may

inclu

de:

o

Crea

ting

auto

mat

ed d

ashb

oard

o

Mon

itorin

g no

less

than

3X

per m

onth

o

Ensu

ring

quar

terly

revie

w/an

alys

is cy

cle

o

Deve

lopi

ng im

prov

emen

t pro

cess

and

pla

ns fo

r met

rics

that

fall s

hort

of s

tand

ards

OUT

COM

ES:

Perfo

rman

ce v

ersu

s st

akeh

olde

r ex

pect

atio

ns (b

eyon

d ba

sic c

ompl

ianc

e)

No

cus

tom

er s

atisf

actio

n su

rvey

in p

lace

Aw

aitin

g sa

tisfa

ctio

n in

form

atio

n co

llect

ed v

ia o

ther

cha

nnel

s (e

.g.,

Tell Y

our S

tory

)

Pe

riodi

c m

eetin

gs w

ith o

ther

sta

keho

lder

s (i.

e., b

anks

, pru

dent

ial

regu

lato

rs)

Co

nsum

er R

espo

nse

Stee

ring

Com

mitte

e cr

eate

s fo

rmal

ity to

re

info

rce

coor

dina

tion

with

in C

FPB

No

form

al a

sses

smen

t yet

of p

erfo

rman

ce v

s. e

xpec

tatio

ns

Med

ium

Bu

reau

sho

uld

ram

p up

cus

tom

er s

atisf

actio

n su

rvey

pro

cess

as

soon

as

poss

ible

Bu

reau

sho

uld

cons

ider

em

ploy

ing

conc

ept o

f an

“ann

ual C

FPB

scor

ecar

d” to

sum

mar

ize k

ey m

etric

s an

d an

ticip

ated

im

prov

emen

t initia

tives

for d

istrib

utio

n to

full s

take

hold

er b

ase

- wa

y to

form

alize

feed

back

col

lect

ion/

use

Bu

reau

sho

uld

cons

ider

dev

elop

ing

para

llel te

am to

inte

rnal

Co

nsum

er R

espo

nse

stee

ring

com

mitte

e via

a fo

rmal

(rot

atin

g m

embe

rshi

p) s

take

hold

er a

dviso

ry b

oard

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

47

Fact

or

Scor

e Su

mm

ary

of P

erfo

rman

ce

Prio

rity

Find

ing

/ Rec

omm

enda

tion

OUT

COM

ES:

Link

age

betw

een

mea

sure

men

t and

co

ntin

uous

pro

cess

im

prov

emen

t

An

ecdo

tal u

se o

f sta

keho

lder

feed

back

to tw

eak

exist

ing

proc

esse

s (e

.g.,

bank

por

tal)

Co

ntac

t cen

ter:

call s

corin

g an

d ot

her r

elat

ed Q

A/pr

oces

s im

prov

emen

t und

erwa

y wi

th s

mal

l QC

team

Bu

t for

mal

mea

sure

men

t sys

tem

s la

rgel

y at

ear

liest

sta

ges

of

deve

lopm

ent t

oday

out

side

of in

take

/con

tact

cen

ter

Med

ium

Bure

au s

houl

d co

ntin

ue w

ith re

leva

nt Q

C an

d da

ta h

ires

to

reso

urce

mea

sure

men

t, in

spec

tion,

repo

rting

and

rela

ted

anal

ysis

– a

core

par

t of C

R’s

man

date

OUT

COM

ES: Q

uality

of

repo

rting

to in

form

fu

ture

CFP

B sc

ope,

re

duce

com

plai

nts

over

time

No

spe

cific

oper

atio

nal g

oals

in p

lace

to d

ate

rega

rdin

g m

inin

g co

ntac

ts c

lass

ified

as “f

eedb

ack”

Lo

w

Bu

reau

sho

uld

cont

inue

with

rele

vant

QC

and

data

hire

s to

re

sour

ce m

easu

rem

ent,

insp

ectio

n, re

porti

ng a

nd re

late

d an

alys

is

Bu

reau

sho

uld

esta

blish

sin

gle

mas

ter d

ashb

oard

cor

e op

erat

ing

met

rics

on s

lides

30

and

31

Bu

reau

sho

uld

set in

tern

al s

tand

ards

for m

inin

g fe

edba

ck, b

oth

as a

saf

egua

rd to

ens

ure

inco

rrect

ly co

ded

feed

back

is re

rout

ed

if nec

essa

ry, a

nd to

pro

vide

fresh

dat

a/an

alys

is on

pro

cess

im

prov

emen

t, em

ergi

ng c

onsu

mer

con

cern

s/ne

eds,

etc

.


49

Section 4: Information Technology

4.1 Scope of Audit

In this section, we establish scope boundaries for our audit of CFPB’s performance in the area of Information Technology (IT). Our evaluation of the bureau’s performance in this area has three distinct components: (1) an evaluation of selected IT investments to date (i.e., project performance); (2) an evaluation of current-state operations of the IT investment process; and (3) an evaluation of IT investment process maturity. In order to evaluate performance across these three areas, we leveraged three complementary performance frameworks. In the table below, we introduce the source for each performance framework, and explain how we used the framework to support the performance audit.

Performance Framework Evaluation Use Federal IT Dashboard (http://www.itdashboard.gov/)

Establishes a framework for evaluating the performance of individual IT investments or projects, in terms of cost, schedule, and other performance metrics that are established by agency CIOs.

GAO Report: Assessing Risks and Returns: A Guide for Evaluating Federal Agencies' IT Investment Decision-making (AIMD-10.1.13)

Establishes a framework for evaluating how well an agency is selecting and managing its IT resources, and for identifying improvement opportunities.

GAO Report: Information Technology Investment: A Framework for Assessing and Improving Process Maturity (GAO-04-394G)

Establishes a framework for evaluating the maturity of an IT investment process. This report enhances the guidance from AIMD-10.1.13 through the creation of a formal maturity model for investment management—the Information Technology Investment Management (ITIM) Framework.

4.1.1 Evaluation of Major IT Investments

The first component of our performance audit was an evaluation of selected IT projects that are currently underway at CFPB. The purpose of this component was to determine whether existing IT investments are proceeding according to established plans with respect to scope, schedule, and budget – and whether they are meeting the defined requirements. In order to evaluate performance in this dimension, we used the standards and criteria that defined by the Federal IT Dashboard (FITD). The FITD is a standardized method for all federal agencies to report on the health of their major IT projects, and to support decisions regarding the investment and management of IT resources.

4.1.2 Evaluation of the IT Investment Process

The second component of our performance audit is an evaluation of operations of the IT investment process. The purpose of this component is to evaluate the overall planning and control of the IT investment process, including the methods that CFPB uses to select and manage IT projects, as well as the standards that are used to determine whether IT investments are supporting strategic goals. In


50

order to evaluate performance in this dimension, we used the standards and criteria that are defined in GAO’s framework for evaluating Federal IT investment decision-making. This framework is based on three inter-connected dimensions:

Selection. Setting priorities and making decisions regarding which IT projects should be funded.

Control. Managing projects throughout the development lifecycle in order to ensure that projects deliver their intended results.

Evaluation. Comparing actual results against expected results and assessing the project’s impact on mission performance.

4.1.3 Evaluation of IT Investments Maturity

The third component of our performance audit was an evaluation of the maturity of CFPB’s IT investment process. In order to evaluate performance in this dimension, we used the standards and criteria that are defined by GAO’s Information Technology Investment Management (ITIM) Framework. This framework defines five progressive stages of maturity for IT investment management – and for each stage, it describes a set of criteria that must be in place to achieve that stage.

GAO developed the ITIM to be used both as a tool for organizational improvement, and as a standard against which to judge the maturity of an organization’s IT investment management process. The specific maturity levels and associated criteria of the ITIM framework are described in greater detail in Section 4.2.3.2.




The Dodd-Frank Act did not specifically establish requirements and/or evaluation criteria in the area of IT Systems. However, there are laws that establish standards and criteria for IT systems and IT investment processes. Chief among them are the following:

E-Government Act of 2002 (Public Law 107-347, 116 Stat. 2899, 44 U.S.C. § 101, H.R. 2458/S. 803), United States statute enacted on December 17, 2002, with an effective date for most provisions of April 17, 2003. Its stated purpose is to improve the management and promotion of electronic government services and processes by establishing a Federal Chief Information Officer within the Office of Management and Budget, and by establishing a framework of measures that require using Internet-based information technology to improve citizen access to government information and services, and for other purposes.


51

Federal Information Security Management Act of 2002 (FISMA) (44 U.S.C. § 3541, et seq). United States federal law enacted in 2002 as Title III of the E-Government Act of 2002 (Pub.L. 107-347, 116 Stat. 2899). The act recognized the importance of information security to the economic and national security interests of the United States. The act requires each federal agency to develop, document, and implement an agency-wide program to provide information security for the information and information systems that support the operations and assets of the agency, including those provided or managed by another agency, contractor, or other source.

Confidential Information Protection and Statistical Efficiency Act (CIPSEA). This statute prohibits disclosure or release, for non-statistical purposes, of information collected under a pledge of confidentiality. Under CIPSEA, data may not be released to unauthorized persons.

The Clinger-Cohen Act of 1996 (formally the Information Technology Management Reform Act, Division E of Public Law 104-106) The Clinger-Cohen Act requires federal agencies to focus on the results they are achieving through IT investments. Specifically, the act introduces much more rigor and structure into how agencies approach the selection and management of IT projects. Among other things, the head of each agency is required to implement a process for maximizing the value and assessing and managing the risks of the agency's IT acquisitions.

The Paperwork Reduction Act of 1995 (PRA) (Public Law 104-13). PRA requires agencies to use information resources to improve the efficiency and effectiveness of their operations and fulfillment of their missions. It emphasizes achieving program benefits and meeting agency goals through the effective use of IT.

The Federal Acquisition Streamlining Act of 1994 (FASA) (Public Law 103-355). Title V of FASA requires agencies to define cost, schedule, and performance goals for federal acquisition programs (including IT projects) and to monitor these programs to ensure that they remain within prescribed tolerances. If a program falls out of tolerance (failure to meet 90 percent of cost, schedule, and performance goals), FASA gives the agency head the authority to review, and if necessary terminate, the program.


In order to assess achievement of organizational goals, we evaluated the progress that CFPB has made towards measurable goals that are documented in its planning artifacts. The bullets below describe the five goals that were documented in CFPB’s Information Technology Roadmap:

Hire/Retain World Class Talent o Be great at sourcing world-class candidates o Seek people who share our values and align with our mission o Establish an interview process that is rigorous and fair o Demonstrate commitment to the professional development of our team o Create an environment that fosters work/life balance & career growth

Lay the Technology Foundation

o Place top priority on safety and securing the public trust o Deliver geographically agnostic, reliable access to our network


52

o Use technology to simplify and improve processes for our customers, don’t impose burdens on them

o Seek enterprise-wide solutions to common problems o Value openness and transparency in all we do

Drive the Data Architecture o Develop systems and policies to clean, merge, and store data o Help acquire key data and facilitate expansive analyses o Structure environments to support wide array of analysis tools o Centralize collection through an enterprise wide data warehouse o Provide exceptional tools for reporting and analysis

Provide Customer Focused IT Services

o Constantly monitor CFPB needs and external technology trends o Focus on understanding problems first, technology second o Provide responsible governance over the IT platform portfolio o Make it faster, easier, and better to work with IT o Be ambassadors internally and externally for great IT

Create Engaging Digital Experiences o Deliver an engaging website experience with useful tools o Build data and content APIs for external use o Develop and integrate applications for internal use o Focus on a highly useful mobile experience o Provide open source code for other government agencies to use


In order to evaluate alignment with performance standards and best practices, we used the standards and criteria defined by three federal IT performance frameworks: (1) GAO’s Guide for Evaluating IT Investment Decision-Making; (2) GAO’s Information Technology Investment Management (ITIM) Framework; and (3) the Federal IT Dashboard. Each of these performance frameworks is made up of several dimensions of performance, as well as criteria and/or examples that constitute effective performance. Below, we describe the dimensions and criteria that make up each of the three performance frameworks.

4.2.3.1 GAO’s Guide for Evaluating IT Investment Decision-making

In order to evaluate the IT investment management process, we use standards and criteria defined by GAO in its Guide for Evaluating IT Investment Decision-Making.3 GAO’s framework is built around three phases of IT investment management (Selection, Control and Evaluation) – as well as three levels of review (Process, Data and Decisions). As illustrated in the diagram below, the intersection of these three phases and review levels creates a matrix of nine performance areas.

3 GAO, Assessing Risk and Returns: A Guide for Evaluating Federal Agencies’ IT Investment Decision-making, GAO-AIMD-10.1.13 (Washington, D.C.: February 1997).


53

Within each performance area, GAO has defined specific criteria or “key elements”, which we use to evaluate performance for the CFPB’s IT investment process. For example, specific criteria related to the Selection dimension include the following:

Does the organization have a defined process for submitting and screening new funding proposals for management consideration? Is this process established in policy guidance?

Does the selection process define (1) what information is to be submitted, (2) who must approve (screen) the information prior to formal submission, (3) how a determination will be made about where in the organization the project will be reviewed, and (4) the stages of management review?

Are roles, responsibilities, and authority for people and offices involved in the screening process clearly defined?

4.2.3.2 GAO’s Information Technology Investment Management (ITIM) Framework

In order to evaluate the CFPB’s investment management maturity, we use standards and criteria that are defined in GAO’s ITIM Framework.4 This framework is built around five progressive stages of maturity for IT investment management (Stages 1 through 5). As illustrated in the diagram below, each stage of maturity is indicated by the presence of certain “critical processes”. For example, critical processes for advancement past Stage 1 maturity include the creation of an investment review

4 GAO, Information Technology Investment Management: A Framework for Assessing and Improving Process Maturity, GAO-04-394G (Washington, D.C.: March 2004).


54

board and development of an investment selection process. We use the presence of these critical processes as criteria to evaluate the maturity CFPB’s IT investment management process.

4.2.3.3 Federal IT Dashboard (FITD)

The FITD is a standardized method for all federal agencies to report on the health of their major IT projects. Following the FITD methodology, each IT project receives an overall investment rating, which is a composite of three component scores (cost, schedule, and Evaluation by Agency CIO).5 The “Evaluation by Agency CIO” dimension is determined by each agency CIO, using a pre-defined set of evaluation factors and criteria, as illustrated in the table below. The bullets below describe the criteria that we used to evaluate IT project performance:

Risk Management o Does a risk management strategy exist? o Are risks well understood by senior leadership? o Is the risk log current and complete? o Are risks clearly prioritized? o Are mitigation plans in place to address risks?

Requirements Management

o Are investment objectives clear? o Is scope controlled? o Are requirements complete, clear and validated? o Are appropriate stakeholders involved in requirements definition?

Contractor Oversight o Is the acquisition strategy defined and managed via an Integrated Program Team?

5 Federal IT Dashboard, FAQ - For Agencies, http://www.itdashboard.gov/faq-agencies (September 2, 2011)


55

o Does the agency receive key reports, such as earned value reports, current status, and risk logs?

o Is the agency providing appropriate management of contractors such that the government is monitoring, controlling, and mitigating the impact of any adverse contract performance?

Historical Performance o Are there significant deviations from planned cost and schedule? o Are lessons learned and best practices incorporated and adopted?

Human Capital o Is there a qualified management and execution team for the IT investments? o Are contracts in place to support the investment? o Is there a low turnover rate among project resources?

Cost. The cost criterion is assessed in terms of percent cost variance. Cost variance of less

than 10% results in a “Green” stoplight rating; cost variance of 10% to <30% results in a “Yellow” rating; and cost variance of 30% or more results in a “Red” rating.

Schedule. The Schedule criterion is assessed in terms of percent schedule variance. Schedule variance of less than 10% results in a “Green” stoplight rating; schedule variance of 10% to <30% results in a “Yellow” rating; and schedule variance of 30% or more results in a “Red” rating.




Table 12 presents our assessment of the CFPB’s compliance with legal requirements. Each row in this table corresponds to a specific legal requirement. For each requirement, we describe the progress that the bureau has demonstrated to date, along with recommendations for future action. The bullets below highlight our key findings and recommendations:

CFPB has developed an innovative web presence that helps the bureau to both educate and listen to consumers, in accordance with eGovernment Act objectives. We recommend that CFPB continue to expand its delivery of services via the Internet as planned, specifically including the addition of “products” to the domain of the Consumer Information System (CIS).


56

CFPB has complied with key elements of the E-Government Act of 2002, including the Federal Information Security Management Act (FISMA) and the Confidential Information Protection and Statistical Efficiency Act (CIPSEA). Specifically, CFPB obtained authority to operate (ATO) for: (1) connectivity to the Treasury infrastructure; and (2) protection of confidential and/or personal information in CIS. We recommend that CFPB continue their approach to retaining personal information and conducting FISMA audits. CFPB has already demonstrated behaviors consistent with this, for example, by submitting System of Record Notices (SORN) that address items such as the individuals covered by the system, categories of records in the system, purpose of the system, categories of users of the system, storage, retrievability, and safeguards.

CFPB has aligned its information technology assets with its strategic missions, in accordance with the Clinger-Cohen Act of 1996. This alignment is managed by the IRB, and documented at a high level through the IRB dashboard. Specifically, the IRB dashboard identifies each of the Initial Systems (technology assets) being developed by CFPB, and links each asset to either: (1) a specific element of CFPB’s mission; or (2) a specific enterprise or business service. The IT department enters proposed IT investments into the dashboard as proposals are received from the business areas and the IRB reviews each investment on a weekly basis. The IRB review is the management mechanism for implementing the capital planning and investment control processes for IT systems.


Table 13 presents our assessment of the CFPB’s achievement of organizational goals. Each row in this table corresponds to a specific organizational goal. For each goal, we describe the progress that the bureau has demonstrated to date, along with recommendations for future action. The bullets below highlight our key findings and recommendations

CFPB should continue to build human capital for the IT function. CFPB has made appropriate progress towards this goal. It has named a Chief Technology Officer, Chief Information Officer and Chief Information Security Officer – and it has established a productive IT organization through an integrated team of government and contractor personnel. We recommend that the IT organization target an 8% to 10% ratio of IT staff to total CFPB staff.

CFPB should form an IT program management office (PMO) to facilitate a continuation of its customer focus and implementation of key systems. The IT department has achieved its goal of laying the technical foundation for CFPB and providing customer focused services. Adopting a PMO approach would provide a means of standardizing artifacts across projects and facilitate development of a project database to support evaluations and a “lessons learned” process.

CFPB has used Information Technology (IT) to support customer service. With the development of the Consumer Information System (CIS) and the CFPB website, the IT department has created an engaging digital experience. The use of Tell Your Story and Know Before You Owe on the website offer further evidence of progress in this area. We


57

recommend that the IT organization continue its emphasis on this goal and conduct a formal review of the usability of the website.


Table 14 (Investment Review Process) presents our assessment of the CFPB’s performance with respect to IT Investment Management. Each row in this table corresponds to an evaluation factor specified in GAO ITIM framework. Table 15 presents our summary assessment of performance for three IT projects that are currently being managed by the CFPB (eDiscovery, Consumer Information System, and Cornerstone). For each row in these tables, we provide the following information: (1) a rating of CFPB’s performance to date, using a stoplight scale (i.e., Red, Yellow or Green); (2) a summary of demonstrated performance; (3) the priority of future progress in this area; and (4) recommendations for future action. The bullets below highlight our key findings and recommendations.

CFPB should initiate a formal evaluation process for IT investments. We found that the

project selection and project control components of CFPB’s IT investment management process met GAO standards, as defined in the Information Technology Investment Management (ITIM) Framework. We recommend that CFPB initiate a formal investment evaluation process, now that it has a growing set of historical data regarding the performance of IT projects. The evaluation process should be a function of the Investment Review Board (IRB) and supported by the PMO.

CFPB’s IT investment management process is operating at “stage two” of the five-stage maturity model defined by the GAO’s ITIM Framework. In order to progress to stage three, CFPB should build upon existing IRB processes, with an emphasis on: (1) grouping similar investments together and developing an IT portfolio; (2) creating and maintaining portfolio selection criteria; (3) examining the merits of each IT investment in the context of the portfolio; and (4) using an Enterprise Architecture to help align IT investments with strategic objectives.

CFPB should develop and apply standard methods to manage risk and cost variance for IT investments. Using the Federal IT Dashboard as a performance standard to evaluate three projects, we found evidence of good requirements management, contractor oversight, human capital, and schedule management. We recommend that the IT department apply a standard method to monitor and manage cost variance, even though many projects are performed on a fixed cost basis. Also, we recommend that CFPB adopt a standardized approach to documenting risks and mitigation strategies.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

58

Tab

le 1

2: C

omp

lian

ce w

ith

Leg

al R

equ

irem

ents

Lega

l Req

uire

men

t De

mon

stra

ted

Perfo

rman

ce

Find

ing

/ Rec

omm

enda

tion

E-G

over

nmen

t Act

(eG

ov) o

f 200

2 –

Prom

otes

use

of e

lect

roni

c go

vern

men

t ser

vices

Title

III:

Fede

ral I

nfor

mat

ion

Secu

rity

Man

agem

ent A

ct (F

ISM

A) o

f 20

02 –

Req

uire

s ea

ch fe

dera

l age

ncy

to d

evel

op, d

ocum

ent,

and

impl

emen

t an

agen

cy-w

ide

prog

ram

to p

rovid

e in

form

atio

n se

curit

y

Title

V: C

onfid

entia

l Inf

orm

atio

n Pr

otec

tion

and

Stat

istic

al

Effic

ienc

y Ac

t (CI

PSEA

). Pr

ohib

its d

isclo

sure

or r

elea

se, f

or n

on-

stat

istica

l pur

pose

s, o

f info

rmat

ion

colle

cted

und

er a

ple

dge

of

conf

iden

tiality

. Und

er C

IPSE

A, d

ata

may

not

be

rele

ased

to

unau

thor

ized

pers

ons.

• M

ultip

le in

itiativ

es d

emon

stra

te th

e CF

PB’s

focu

s on

in

form

ing

and

liste

ning

to c

onsu

mer

s in

inno

vativ

e wa

ys (C

FPB

webs

ite, K

now

Befo

re Y

ou O

we,

publ

ishin

g le

ader

ship

cal

enda

rs).

• Ap

poin

ted

a Ch

ief I

nfor

mat

ion

Offic

er a

nd C

hief

In

form

atio

n Se

curit

y O

fficer

. •

Com

plet

ed in

itial p

hase

of t

he C

onsu

mer

Info

rmat

ion

Syst

em (C

IS),

inclu

ding

the

abilit

y to

rece

ive c

redi

t ca

rd c

ompl

aint

s fro

m c

onsu

mer

s.

• Re

ceive

d Au

thor

izatio

n To

Ope

rate

(ATO

) for

in

frast

ruct

ure

and

conn

ectiv

ity to

Tre

asur

y ne

twor

k an

d sy

stem

s. F

ISM

A pr

oces

ses

are

impl

emen

ted.

•

Syst

ems

such

as

CIS

and

eDisc

over

y –

which

may

co

ntai

n co

nfid

entia

l or p

erso

nally

iden

tifiab

le

info

rmat

ion

(PII)

–ha

ve s

afeg

uard

s to

pre

vent

the

rele

ase

of th

is in

form

atio

n to

una

utho

rized

per

sons

.

Cont

inue

with

pla

ns to

impr

ove

the

webs

ite a

nd

furth

er d

evel

op C

IS.

Deve

lop

perfo

rman

ce m

easu

res

for e

-go

vern

men

t tha

t are

: (1)

citiz

en-c

entri

c; (2

) pr

oduc

tivity

rela

ted;

and

(3) l

inke

d to

the

CFPB

’s St

rate

gic

Plan

s.

Cond

uct P

rivac

y Im

pact

Ass

essm

ents

for a

ll ap

plica

ble

IT s

yste

ms.

Deve

lop

annu

al e

-Gov

ernm

ent R

epor

t to

Cong

ress

.

Impl

emen

t ann

ual F

ISM

A au

dits

.

Esta

blish

pol

icies

and

pro

cedu

res

to s

uppo

rt th

e de

tect

ion,

ass

essm

ent,

and

mitig

atio

n of

risk

s th

at

coul

d re

sult f

rom

una

utho

rized

or i

napp

ropr

iate

us

e of

org

aniza

tiona

l info

rmat

ion.

The

Clin

ger-C

ohen

Act

of 1

996

(form

ally

the

Info

rmat

ion

Tech

nolo

gy

Man

agem

ent R

efor

m A

ct, D

ivisio

n E

of P

ublic

Law

104

-106

) - R

equi

res

fede

ral a

genc

ies

to fo

cus

on th

e re

sults

they

are

ach

ievin

g th

roug

h IT

in

vest

men

ts.

• Te

chno

logy

inve

stm

ents

are

tied

to C

FPB

miss

ion

elem

ents

(e.g

., CI

S –

cons

umer

pro

tect

ions

; eD

iscov

ery,

law

enfo

rcem

ent)

or to

non

-miss

ion

elem

ents

that

dire

ctly

impa

ct th

e m

issio

n (e

.g.,

hum

an

capi

tal, f

inan

cial m

anag

emen

t).

• Pr

otot

ype

impl

emen

tatio

ns a

re u

sed

to re

duce

the

risk

of IT

pro

ject

s, a

s in

the

case

of t

he C

IS “b

ridge

” pro

ject

. •

Agile

dev

elop

men

t met

hods

are

use

d to

del

iver

bene

fits in

man

agea

ble

incr

emen

ts.

Stan

d up

a fo

rmal

Pro

gram

Man

agem

ent O

ffice

for C

FPB

Info

rmat

ion

Tech

nolo

gy.

Impl

emen

t a

portf

olio

app

roac

h to

IT in

vest

men

t man

agem

ent,

inclu

ding

ana

lysis

of re

turn

s on

eac

h in

vest

men

t.

The

Pape

rwor

k Re

duct

ion

Act (

PRA)

of 1

995

- Req

uire

s ag

encie

s to

us

e in

form

atio

n re

sour

ces

to im

prov

e th

e ef

ficie

ncy

and

effe

ctive

ness

of

thei

r ope

ratio

ns a

nd fu

lfillm

ent o

f the

ir m

issio

ns.

• M

ultip

le IT

inve

stm

ents

(e.g

., CI

S, e

-Disc

over

y,

webs

ite) u

tilize

info

rmat

ion

tech

nolo

gy to

: (1)

impr

ove

the

perfo

rman

ce o

f bur

eau

miss

ion;

(2) p

rom

ote

acce

ss to

info

rmat

ion;

and

/or (

3) m

inim

ize th

e bu

rden

of

info

rmat

ion

colle

ctio

n on

the

publ

ic.

• Th

e IR

B da

shbo

ard

dem

onst

rate

s th

at C

FPB

appl

ies

info

rmat

ion

reso

urce

s to

sup

port

thei

r miss

ion.

Cont

inue

to id

entify

mea

ning

ful IT

inve

stm

ents

an

d us

e th

e es

tabl

ished

IRB

proc

ess

to s

elec

t an

d tra

ck th

e IT

inve

stm

ents

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

59

Lega

l Req

uire

men

t De

mon

stra

ted

Perfo

rman

ce

Find

ing

/ Rec

omm

enda

tion

The

Fede

ral A

cqui

sitio

n St

ream

linin

g Ac

t (FA

SA) o

f 199

4 - R

equi

res

agen

cies

to d

efin

e co

st, s

ched

ule,

and

per

form

ance

goa

ls fo

r fed

eral

ac

quisi

tion

prog

ram

s (in

cludi

ng IT

pro

ject

s) a

nd to

mon

itor t

hese

pr

ogra

ms

to e

nsur

e th

at th

ey re

mai

n wi

thin

pre

scrib

ed to

lera

nces

.

• CF

PB p

roje

cts

have

def

ined

bud

gets

and

sch

edul

es

that

are

app

rove

d by

the

IRB.

All p

roje

cts

repo

rt st

atus

in

form

atio

n to

the

IRB,

and

pro

gres

s is

mon

itore

d th

roug

h th

e IR

B da

shbo

ard.

How

ever

, sta

tus

info

rmat

ion

does

not

inclu

de e

arne

d va

lue

repo

rts o

r fo

rmal

risk

logs

.

Cont

inue

the

IRB

proc

ess

and

add

a PM

O

com

pone

nt to

man

age

cost

and

sch

edul

ing

info

rmat

ion

on a

sta

ndar

dize

d ba

sis.

Cons

ider

em

ploy

ing

Earn

ed V

alue

Man

agem

ent (

EVM

) or

othe

r pro

ject

man

agem

ent m

etric

s as

nee

ded

as

the

orga

niza

tion

grow

s.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

60

Tab

le 1

3: A

chie

vem

ent

of O

rgan

izat

ion

al G

oals

Org

aniz

atio

nal G

oal

Dem

onst

rate

d Pe

rform

ance

Fi

ndin

g / R

ecom

men

datio

n

Hire

/Ret

ain

Wor

ld C

lass

Tal

ent

• Ke

y po

sitio

ns (C

IO, C

TO, a

nd C

ISO

) are

fille

d, a

dditio

nal p

ositio

ns a

re

bein

g fill

ed in

acc

orda

nce

with

hig

h le

vel p

lans

, and

con

sultin

g su

ppor

t is

in p

lace

to a

ddre

ss p

eak-

load

wor

k.

• Th

e IT

org

aniza

tion

shou

ld c

ontin

ue to

add

app

ropr

iate

sta

ff to

mai

ntai

n a

ratio

of b

etwe

en 8

% to

10%

as

com

pare

d to

th

e to

tal s

taff

of C

FPB.

Lay

the

Tech

nolo

gy F

ound

atio

n

• DC

loca

tions

con

nect

ed, r

egio

nal lo

catio

n in

frast

ruct

ure

and

conn

ectio

ns

depl

oyed

, har

dwar

e fo

r inc

omin

g em

ploy

ees

proc

ured

& d

eplo

yed,

ex

trane

t des

igne

d, m

igra

tion

to C

FPB

LAN/

WAN

pla

nned

, inde

pend

ent

disa

ster

reco

very

/bac

k up

pla

n (c

urre

ntly

falls

und

er T

reas

ury’s

pla

n)

unde

r dev

elop

men

t.

• Th

e IT

org

aniza

tion

shou

ld c

ontin

ue to

incr

ease

its n

etwo

rk

capa

city.

Dev

elop

and

test

a C

ontin

uity

of O

pera

tions

Pla

n (C

OO

P) th

at is

spe

cific

to C

FPB,

with

in th

e Tr

easu

ry's

larg

er

plan

.

Drive

the

Data

Arc

hite

ctur

e

• En

terp

rise-

wide

dat

a st

rate

gy h

as b

een

deve

lope

d an

d in

clude

s da

ta

arch

itect

ure,

tool

/sof

twar

e ar

chite

ctur

e, a

nd d

ata

secu

rity

• Pr

oces

ses

and

proc

edur

es a

re d

efin

ed

• Sh

ort t

erm

, mid

-term

, and

long

-term

pla

ns a

re d

ocum

ente

d

• Th

e IT

org

aniza

tion

shou

ld fo

rmal

ize a

n or

gani

zatio

nal

taxo

nom

y an

d en

terp

rise

data

dict

iona

ry.

Prov

ide

Cust

omer

Foc

used

IT S

ervic

es

• eD

iscov

ery

solu

tion

has

been

acq

uire

d an

d in

itial d

ata

has

been

ca

ptur

ed.

• In

itial fu

nctio

nality

of t

he C

IS s

yste

m (c

redi

t car

d co

mpl

aint

s) is

onl

ine

and

addi

tiona

l pro

duct

type

s (m

ortg

ages

, stu

dent

loan

s, e

tc.)

are

sche

dule

d fo

r sup

port

• Co

ntin

ued

supp

ort is

pro

vided

to th

e IR

B •

Inhe

rited

sys

tem

s ar

e be

ing

supp

orte

d •

Asse

t Tra

ckin

g an

d Co

mpl

ianc

e To

olkit

/Risk

Ana

lytics

sys

tem

pla

ns h

ave

been

app

rove

d by

the

IRB

• Th

e IT

org

aniza

tion

shou

ld fo

rmal

ize p

roje

ct a

rtifa

cts

per

what

is ty

pica

lly fo

und

in a

PM

O.

Crea

te E

ngag

ing

Digi

tal E

xper

ienc

es

• Fe

edba

ck m

echa

nism

s de

velo

ped

for C

FPB

webs

ite (e

.g.,

Cred

it Car

d Co

mpl

aint

s, T

ell Y

our S

tory

, Ope

n fo

r Com

men

t).

• He

at m

ap d

ispla

ys o

f fee

dbac

k fro

m K

now

Befo

re Y

ou O

we p

roje

ct.

• W

ebsit

e us

e st

atist

ics

• Th

e IT

org

aniza

tion

shou

ld p

erfo

rm fo

rmal

use

r tes

ting

of

the

publ

ic fa

cing

webs

ites

once

the

sites

are

mor

e m

atur

e.

This

shou

ld in

clude

hea

t map

s, u

sabi

lity te

sts,

clic

k co

unts

, et

c.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

61

Tab

le 1

4: A

lign

men

t w

ith

Per

form

ance

Sta

nd

ard

s (I

nve

stm

ent

Rev

iew

Pro

cess

)

Fact

or

Scor

e Su

mm

ary

of P

erfo

rman

ce

Prio

rity

Find

ing

/ Rec

omm

enda

tion

Sele

ctio

n

Al

l IT in

vest

men

ts g

reat

er th

an $

100K

are

eva

luat

ed b

y th

e IR

B an

d do

cum

ente

d on

the

IRB

Dash

boar

d

Th

e IR

B ha

s a

sele

ctio

n pr

oces

s in

pla

ce th

at in

clude

s co

st a

nalys

is,

alte

rnat

ives

anal

ysis,

sch

edul

ing,

and

gov

ernm

ent c

ost e

stim

ates

. De

cisio

ns

are

docu

men

ted

with

exp

lana

tions

. Exc

eptio

ns to

the

proc

ess

are

for

emer

genc

ies

and

a sig

n-of

f she

et is

requ

ired

Th

e IR

B ha

s es

tabl

ished

info

rmat

ion/

repo

rting

requ

irem

ents

for c

andi

date

in

vest

men

ts a

nd fo

r in-

flight

pro

ject

s.

IR

B da

shbo

ard

is up

date

d we

ekly.

Pro

ject

s ar

e m

onito

red

base

d on

in

form

atio

n fro

m th

e da

shbo

ard.

Med

ium

Th

e IR

B wa

s es

tabl

ished

ver

y ea

rly in

the

CFPB

org

anizi

ng

proc

ess.

It h

as m

et w

eekly

in o

rder

to a

ddre

ss c

ritica

l and

fast

m

ovin

g ne

eds.

As

the

orga

niza

tion

mat

ures

the

IRB

shou

ld: (

1)

adop

t a p

ortfo

lio a

ppro

ach

to IT

inve

stm

ent m

anag

emen

t; (2

) de

velo

p fo

rmal

met

rics

and

stan

dard

s fo

r pro

ject

sco

ring

and

sele

ctio

n; a

nd (3

) ret

ain

cons

isten

t per

form

ance

dat

a. T

he

portf

olio

app

roac

h wi

ll be

need

ed to

sup

port

budg

et fo

rmul

atio

n go

ing

forw

ard.

Cont

rol

Pe

rform

ance

met

rics

are

mai

ntai

ned,

but

EVM

cal

cula

tions

are

not

pe

rform

ed.

The

IRB

does

not

man

date

the

use

of s

pecif

ic m

etric

s or

th

resh

olds

, and

it do

es n

ot a

pply

diffe

rent

met

rics

for p

roje

cts

of d

iffere

nt s

ize.

Ex

cel s

prea

dshe

ets

are

used

to m

aint

ain

inve

stm

ent in

form

atio

n

Af

ter A

ctio

n Re

views

are

con

duct

ed a

nd d

ocum

ente

d

Di

spos

ition

proc

ess

is be

ing

plan

ned

– no

t yet

requ

ired

due

to e

arly

stag

e of

or

gani

zatio

n

CF

PB tr

acks

exp

endi

ture

s as

socia

ted

with

IT in

vest

men

ts th

at a

re h

andl

ed

thro

ugh

Mem

oran

da o

f Und

erst

andi

ng (M

OU)

with

ext

erna

l org

aniza

tions

(e

.g.,

Trea

sury

).

High

Th

e IT

org

aniza

tion

mai

ntai

ns p

roje

ct c

ontro

l thro

ugh

spre

adsh

eets

and

var

ious

repo

rting

ven

ues

(slid

es fo

r IRB

). As

th

e or

gani

zatio

n m

atur

es, a

“PM

O-lit

e” a

ppro

ach

is re

com

men

ded

to s

tand

ardi

ze p

roje

ct a

rtifa

cts,

pro

vide

a ce

ntra

l po

rtal to

reta

in p

roje

ct a

rtifa

cts,

form

alize

cos

t and

sch

edul

e va

rianc

e re

porti

ng, a

nd e

stab

lish

stan

dard

ized

met

rics

typi

cal o

f a

mat

ure

proj

ect m

anag

emen

t app

roac

h. T

he IR

B pr

oces

s sh

ould

hav

e de

taile

d do

cum

enta

tion

and

supp

ortin

g po

licy

that

do

veta

ils w

ith th

e PM

O.

Eval

uatio

n

Th

e IR

B co

nduc

ted

its fir

st fo

rmal

revie

w of

an

in-fl

ight

pro

ject

in S

epte

mbe

r 20

11.

The

stat

us re

port

deve

lope

d fo

r thi

s in

itial p

roje

ct re

view

will b

e us

ed

as a

tem

plat

e fo

r fut

ure

proj

ect r

evie

ws.

Th

e IR

B pr

oces

s is

eval

uate

d an

d re

vised

as

the

orga

niza

tion

mat

ures

Th

ere

is ve

ry lim

ited

post

-impl

emen

tatio

n re

view

info

rmat

ion

beca

use

proj

ects

are

in th

e ea

rly p

hase

s of

the

syst

ems

deve

lopm

ent li

fecy

cle

Med

ium

In

add

ition

to th

e ad

hoc

Afte

r Act

ion

Revie

ws (A

AR) t

hat t

he IT

or

gani

zatio

n cu

rrent

ly pe

rform

s, s

tand

ardi

zed

and

regu

larly

sc

hedu

led

revie

ws a

re re

com

men

ded.

Thi

s wi

ll be

facil

itate

d by

es

tabl

ishin

g th

e PM

O fu

nctio

n an

d pr

ojec

t man

agem

ent p

orta

l th

at w

ill ca

ptur

e da

ta n

eede

d fo

r the

revie

ws. T

his

is hi

ghly

reco

mm

ende

d as

maj

or p

roje

cts

com

plet

e th

e im

plem

enta

tion

phas

e (fi

rst r

elea

ses)

. Pos

t Im

plem

enta

tion

Revie

w (P

IR) s

houl

d be

com

e an

IRB

agen

da ite

m.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

62

Tab

le 1

5: A

lign

men

t w

ith

Per

form

ance

Sta

nd

ard

s (I

T P

roje

ct P

erfo

rman

ce)

Fact

or

Scor

e Su

mm

ary

of P

erfo

rman

ce

Prio

rity

Find

ing

/ Rec

omm

enda

tion

Risk

M

anag

emen

t

Al

l pro

ject

s re

port

risks

and

mitig

atio

n st

rate

gies

to th

e IR

B on

a w

eekly

ba

sis.

Howe

ver,

none

of t

he th

ree

sam

pled

pro

ject

s m

aint

ains

a fo

rmal

ris

k re

gist

er..

O

n th

e CI

S pr

ojec

t, ris

k wa

s m

anag

ed th

roug

h th

e de

velo

pmen

t of a

sim

plifie

d “b

ridge

” sys

tem

, in p

aral

lel w

ith d

evel

opm

ent o

f the

targ

et s

tate

sy

stem

. Th

e br

idge

sys

tem

ser

ved

as a

fallb

ack

optio

n, a

s we

ll as

a pr

otot

ype

for t

he ta

rget

sta

te s

yste

m.

O

n th

e Co

rner

ston

e pr

ojec

t, ce

rtain

risk

s ar

e m

itigat

ed b

y le

vera

ging

a

prov

en, T

reas

ury-

wide

sol

utio

n.

Med

ium

De

velo

pmen

t of a

sta

ndar

dize

d ap

proa

ch fo

r com

mun

icatin

g an

d tra

ckin

g po

tent

ial r

isk a

nd m

itigat

ion

stra

tegi

es w

ould

be

bene

ficia

l. Thi

s sh

ould

focu

s on

a “r

isk re

gist

er” a

ppro

ach

and

ultim

atel

y fe

ed a

pro

ject

dat

abas

e.

Requ

irem

ents

M

anag

emen

t

O

n al

l pro

ject

s, a

ltern

ative

tech

nolo

gy s

olut

ions

wer

e ev

alua

ted.

On

CIS

proj

ect,

Forre

ster

Res

earc

h wa

s en

gage

d to

obt

ain

info

rmat

ion

on b

est

prac

tices

.

Al

l pro

ject

s en

gage

d in

requ

irem

ents

elic

itatio

n, d

ocum

enta

tion,

and

m

anag

emen

t act

ivitie

s –

at v

aryin

g le

vels

of ri

gor.

O

n th

e eD

iscov

ery

proj

ect,

the

Elec

troni

c Di

scov

ery

Refe

renc

e M

odel

(an

indu

stry

sta

ndar

d) w

as u

sed

as a

bas

elin

e fo

r req

uire

men

ts a

nalys

is.

Agile

met

hods

wer

e us

ed in

sup

port

of re

quire

men

ts m

anag

emen

t.

O

n th

e Co

rner

ston

e pr

ojec

t, a

mas

ter l

ist o

f sys

tem

requ

irem

ents

was

de

velo

ped

by T

reas

ury

and

cros

swal

ked

agai

nst c

apab

ilitie

s of

the

Corn

erst

one

solu

tion.

O

n th

e CI

S pr

ojec

t, de

velo

pmen

t of t

he “b

ridge

” sys

tem

aid

ed in

the

elici

tatio

n an

d va

lidat

ion

of re

quire

men

ts.

Scop

e of

CIS

requ

irem

ents

for

initia

l pro

ject

pha

se w

as d

riven

in p

art b

y sc

hedu

le c

onst

rain

ts.

Low

As

the

orga

niza

tion

grow

s a

tool

or m

etho

dolo

gy s

houl

d be

us

ed to

sta

ndar

dize

the

appr

oach

to re

quire

men

ts

man

agem

ent.

Re

quire

men

ts s

houl

d be

bas

elin

ed a

t maj

or p

roje

ct

mile

ston

es.

Base

lined

requ

irem

ents

sho

uld

be u

sed

for

test

ing

and

to m

onito

r sco

pe v

aria

nce.

As

the

orga

niza

tion

mat

ures

, pro

ject

requ

irem

ents

sho

uld

be

trace

d up

ward

to o

rgan

izatio

nal c

apab

ilitie

s, in

ord

er to

de

mon

stra

te a

lignm

ent w

ith C

FPB

stra

tegy

.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

63

Fact

or

Scor

e Su

mm

ary

of P

erfo

rman

ce

Prio

rity

Find

ing

/ Rec

omm

enda

tion

Cont

ract

or

Ove

rsig

ht

Fo

r all p

roje

cts:

(1) a

n ac

quisi

tion

stra

tegy

was

dev

elop

ed, d

ocum

ente

d,

and

appr

oved

by

the

IRB;

and

(2) a

form

al s

ched

ule

was

deve

lope

d, a

nd

prog

ress

aga

inst

the

sche

dule

is re

porte

d.

Al

l pro

ject

s re

port

stat

us in

form

atio

n to

the

IRB;

pro

gres

s is

mon

itore

d th

roug

h th

e IR

B da

shbo

ard.

Sta

tus

info

rmat

ion

does

not

inclu

de e

arne

d va

lue

repo

rts o

r for

mal

risk

logs

.

Fo

r all p

roje

cts,

con

tract

or o

vers

ight

app

ears

to b

e ap

prop

riate

and

ef

fect

ive. O

n th

e CI

S pr

ojec

t, ad

optio

n of

agi

le m

etho

dolo

gy b

y bo

th

gove

rnm

ent a

nd c

ontra

ctor

team

s co

ntrib

uted

to e

ffect

ive c

omm

unica

tion

and

coor

dina

tion.

Low

Th

e co

ntra

ctor

ove

rsig

ht fu

nctio

n is

prim

arily

per

form

ed a

t the

pr

ojec

t leve

l, with

sum

mar

y re

porti

ng to

the

IRB.

As

the

orga

niza

tion

grow

s, a

uni

form

eva

luat

ion

mec

hani

sm w

ill be

ap

prop

riate

.

Hist

orica

l Pe

rform

ance

No

ne o

f the

pro

ject

s ex

hibi

t sig

nific

ant d

evia

tions

from

pla

nned

sch

edul

e or

bud

get.

Af

ter A

ctio

n Re

views

are

con

duct

ed a

nd re

porte

d.

Si

nce

CFPB

is in

its e

arly

stag

e of

form

atio

n, th

ere

is lim

ited

info

rmat

ion

rega

rdin

g hi

stor

ical p

erfo

rman

ce o

f pro

ject

s. A

s of

9/2

1/20

11, t

he IR

B ha

d on

ly co

nduc

ted

one

form

al re

view

of p

roje

ct p

erfo

rman

ce (e

-FO

IA p

roje

ct).

Med

ium

Si

nce

the

orga

niza

tion

was

rece

ntly

form

ed, h

istor

ical

perfo

rman

ce h

as n

ot b

een

avai

labl

e or

nec

essa

ry. L

esso

ns

lear

ned

have

bee

n do

cum

ente

d in

Afte

r Act

ion

Repo

rts. G

oing

fo

rwar

d, a

dditio

nal s

truct

ure

will b

e re

quire

d in

ord

er to

es

tabl

ish p

erfo

rman

ce m

etric

s, d

evel

op a

nalyt

ical m

etho

ds,

and

inte

rnal

ize le

sson

s le

arne

d ac

ross

the

orga

niza

tion.

Hum

an C

apita

l

Fo

r all s

ampl

ed p

roje

cts,

per

sonn

el a

re in

pla

ce to

exe

cute

the

plan

(e

xecu

tives

, man

agem

ent,

proj

ect t

eam

, con

tract

ors)

.

No

ne o

f the

sam

pled

pro

ject

s cit

ed c

once

rns

rela

ted

to q

ualifi

catio

ns

and/

or tu

rnov

er ra

te a

mon

g pr

ojec

t tea

m.

Low

CF

PB IT

has

bee

n gr

owin

g ra

pidl

y to

add

ress

the

need

s of

th

e ne

w or

gani

zatio

n. S

kills

and

expe

rienc

e of

the

curre

nt s

taff

are

appr

opria

te fo

r the

age

of t

he o

rgan

izatio

n. K

ey p

ositio

ns

have

bee

n fill

ed. A

dditio

nal s

taffin

g is

reco

mm

ende

d to

ad

dres

s CF

PB g

rowt

h an

d Po

rtfol

io a

nd P

MO

nee

ds.

Cost

Var

ianc

e

Fo

r all s

ampl

ed p

roje

cts,

cos

t var

ianc

e is

repo

rted

to b

e m

inim

al.

No

ne o

f the

pro

ject

s is

usin

g a

stan

dard

ized

met

hod

to d

eter

min

e co

st

varia

nce

(e.g

., EV

M).

High

Co

st v

aria

nce

is un

ders

tood

and

man

aged

by

the

orga

niza

tion.

Goi

ng fo

rwar

d, th

is co

mpo

nent

sho

uld

be

mon

itore

d an

d m

anag

ed b

y a

PMO

org

aniza

tion

in o

rder

to

appl

y a

unifo

rm fr

amew

ork

and

colle

ct h

istor

ical p

erfo

rman

ce

data

. EV

M o

r oth

er p

roje

ct m

anag

emen

t met

rics

may

be

need

ed a

s th

e or

gani

zatio

n gr

ows.

Sche

dule

Va

rianc

e

Fo

r all s

ampl

e pr

ojec

ts, s

ched

ule

varia

nce

is m

inim

al.

Proj

ects

hav

e m

et

all r

elev

ant m

ilest

ones

, as

repo

rted

to th

e IR

B.

Low

Sc

hedu

le v

aria

nce

is un

ders

tood

and

man

aged

by

the

orga

niza

tion.

Goi

ng fo

rwar

d, th

is co

mpo

nent

sho

uld

be

mon

itore

d an

d m

anag

ed b

y a

PMO

in o

rder

to a

pply

a un

iform

fra

mew

ork

and

colle

ct h

istor

ical s

ched

ule

varia

nce

data

.


65

Section 5: Communications and Transparency

5.1 Scope of Audit

In order to evaluate CFPB’s performance in the area of Communications and Transparency, we examined the extent to which the bureau has: (1) complied with relevant laws and regulations; (2) achieved organizational goals and objectives; and (3) aligned with industry best practices. Successful communications plans consider the following critical components as a baseline for building a strategy.

Determine Goals, Objectives and Strategies – Determine the end state CFPB would like to reach with respect to communications and transparency initiatives and the strategies to achieve that goal.

Identify Audiences – Identify the specific audiences CFPB wants to engage.

Establish Policies and Processes – Make certain that there are internal policies and processes to ensure that CFPB’s communications strategy can be properly executed.

Develop Key Messages – Develop messages for key audiences, noting that while messages can be different, message consistency across the organization is important.

Identify Vehicles and Materials for Delivery – Identify the vehicles and materials for message delivery that are appropriate for the targeted audiences and materials used.

Define Metrics – Define what success means and identify the metrics CFPB will use to determine how successful it has been in executing its communications strategy.

We recognize that CFPB is a new bureau and as such may not have implemented all aspects of its plan or determined all appropriate criteria. However, we were able to examine the plans it has developed and executed against thus far, along with those it has developed and will execute in the future, assess its performance to date and offer recommendations for consideration in the future. Our audit focuses on major accomplishments and plans, including internal planning documents, memos and processes, media rollout plans, master outreach plans, reports, and media coverage.




The bullets below describe specific provisions of the Dodd-Frank Act and other applicable laws and regulations that establish compliance requirements or standards in the area of Communications and Transparency.


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Section 1013(a)(5) of the Dodd-Frank Act requires that CFPB have an Ombudsman whose responsibilities include focusing on problem resolution between the bureau and regulated entities or other parties.

Section 1014 of the Dodd-Frank Act requires that CFPB create a Consumer Advisory Board

(CAB) that advises and consults with the bureau in the exercise of its functions and provides information on emerging practices in the consumer financial products or services industry, including regional trends and concerns.

Title 10, Section 1013(e) of the Dodd-Frank Act requires that CFPB create the Office of

Servicemember Affairs. A key objective for the Office as delineated in the statute is to “educate and empower servicemembers and their families to make better informed decisions regarding consumer financial products and services”.

Title 10, Section 1013(g) of the Dodd-Frank Act requires that CFPB create the Office of

Financial Protection for Older Americans, defined as individuals 62 years or older. The goal for this office is to establish programs that provide financial literacy and counseling and to work with other community and non-profit organizations that assist seniors.

Title 10, Section 1035 of the Dodd-Frank Act requires that CFPB designate a Private

Education Loan Ombudsman. Included in the duties prescribed for the Ombudsman is a charge to “ensure coordination in providing assistance to and serving borrowers seeking to resolve complaints related to their private education or Federal student loans”.

Title 10, Section 1013(d) of the Dodd-Frank Act requires that CFPB establish the Office of

Financial Education (OFE), which is responsible for educating consumers to help them make better financial decisions. This office is charged to reach out directly to consumers and to coordinate with other offices within CFPB to carry out its mandates.

Freedom of Information Act (FOIA) (Public Law 89-554) – FOIA provides all citizens

with the right of access to federal agency records or information. When a written request for information is received by a federal agency, the agency is required to disclose those records, unless they can be lawfully withheld under nine specific exemptions outlined in the statute. The burden is on the government, not the public, to provide explanation for why information cannot be released.

E-Government Act of 2002 (Public Law 107-347) – The E-Government Act of 2002's

purpose is to improve electronic government services by establishing a Federal Chief Technology Officer, located in the Office of Management and Budget, and creating a framework that requires Internet-based information technology to improve the transparency of and access to government information and services for citizens. The statute includes the Federal Information Security Management Act of 2002 (FISMA) and the Confidential Information Protection and Statistical Efficiency Act (CIPSEA).

Federal Funding and Accountability Transparency Act (FFATA) (Public Law 109-

282) – FFATA requires that all entities or organizations receiving federal funds as of FY 2007


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are disclosed to the public, with the intent to empower all citizens with the ability to hold the government accountable for spending decisions. All information on federal awards are available to the public via www.usaspending.gov, providing transparent information to the public on government spending decisions.


In order to assess achievement of organizational goals, we evaluated the progress that the bureau has made towards measurable goals that are identified in CFPB planning documents. The bullets below describe the specific organizational goals that are included in our analysis. These goals were derived from the CFPB 2011 Public Outreach Plan, planning documents for the Office of Community Affairs, discussions with CFPB stakeholders, and the Office of Consumer Education and Engagement’s (CEE) 6-Month planning document.

The CFPB 2011 Public Outreach Plan established the following objectives: (1) maintain public support; (2) highlight the positive impact the bureau can and will have in the lives of American consumers; and (3) demonstrate the tangible benefits of the bureau to ordinary Americans. To achieve these broad objectives, the bureau has pursued the following organizational goals:

o Build familiarity with the CFPB brand o Engage the public o Explain policy deliverables in plain English o Illustrate the consumer impact o Maximize bureau resources

The Office of Community Affairs’ first year goals established the following objectives: (1) be

a bridge to the community, civil rights and consumer groups by showing the face of CFPB to the public and bringing timely, relevant, reliable information from the field into the bureau to help inform its work; and (2) be a thought leader on financial inclusion by serving the CFPB and the public with up-to-date information and new ideas about developments in expanding financial opportunity. To achieve these broad objectives, the Office of Community Affairs has pursued the following organizational goals:

o Touch most significant national and regional consumer, civil rights, and grassroots advocacy organizations in the financial services space (~200).

o Develop “early warning” information from the field and make available to all CFPB reports and studies from consumer, civil rights, and community groups about impacts of specific financial service products and practices on neighborhoods and communities.

o Create a searchable content resource of those reports and studies, and provide periodic updates for all CFPB staff of the input received from these groups.

o Be a resource to consumer, civil rights and nonprofit organizations, and help all parts of the CFPB to access knowledge and information from those groups.

Within the CEE, the Office of Consumer Engagement established the following overall

objectives: (1) engage the public with new and timely content in multiple formats; (2) build a team with the tools to succeed; (3) deploy an editorial content management system for ConsumerFinance.gov and content we offer elsewhere via electronic channels; and (4) design


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a blueprint for the CFPB “consumer experience” and develop and deploy interactive product and service offerings. Given the early stage of the Office of Consumer Engagement, we evaluated the following deliverables defined by the Office within the CEE’s 6-Month Plan:

o CFPB’s shared vision of the role of engagement and the desired impact on the public of our engagement work

o Organizational structure, position descriptions, career ladders, recruitment plan, and policies to support the work (example, “blog on other sites” policy)

o Blueprint for the CFPB “consumer experience,” concepts for CFPB product and service offerings such as interactive tools, plus plan with timeline to bring one or more of those more significant tools to fruition

o IT solution for editorial workflow and content management system for ConsumerFinance.gov

o Improved business process for generating and clearing content for use on our website and other electronic channels

o 8-10 blog posts each month generated by the Engagement Office, plus support for financial education content in post and tip form generated by the OFE (in addition to posts from around the bureau)

o Consistent promotion of our money education content such as tip of the day to other sites/channels

o Web portals for the empowerment offices plus OFE (My Fi) and Fair Lending o One to two initial offerings to engage the public on money issues or money decision-

making in close cooperation with OFE o Design and implementation of calendar for use of direct email tool o Web streaming capacity (for Office of Servicemember Affairs convening,

enforcement hearings)

Also within CEE, the Office of Servicemember Affairs (OSA) outlined the following overall objectives: (1) educate and empower servicemembers and their families to make better-informed financial decisions; (2) work with Consumer Response to monitor complaints from military and responses to those complaints by CFPB and other federal and state agencies; (3) coordinate efforts among federal and state agencies regarding consumer protection measures relating to consumer financial products and services used by military families; and (4) serve as a subject-matter expert on military consumer financial matters, both within and outside the CFPB. Given the early stage and youth of the Offices of Servicemember Affairs, we evaluated the following deliverables defined by OSA within the CEE’s 6-Month Plan:

o Develop military content for website/social media o Host convening in October concerning best practices in offering financial products to

military o Evaluate financial education at military basic training o Develop revised curriculum for new recruits in coordination with Dept. of Defense o Provide military expertise for Consumer Response: scripts, FAQs, referrals, tailored

assistance o Raise awareness of CFPB/OSA through media, speeches and outreach to business and

government


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It is important to note that CFPB stakeholders consistently expressed that their primary objective is to support the overall mission of the organization, as prescribed by the statute, as well as the stated mission and vision of the bureau. Discussions with CFPB stakeholders revealed the following additional anecdotal goals, including:

o Adhere to all appropriate federal mandates o Maintain the spirit of transparency that was “baked into the organization” at its

inception o Educate the public on what CFPB is and what it is doing to help ordinary Americans o Meet with community bankers from all 50 states


In order to assess achievement of performance standards and best practices, we evaluated the progress CFPB has made against the framework outlined below.

Goals, Objectives and Strategies. A successful communications plan should include well-defined goals and objectives, and the necessary strategies to achieve those goals.

Audiences. Audiences that are important to the CFPB should be identified and an initial assessment should be made regarding their current perception or awareness level of CFPB.

Policies and Processes. Internal policies and processes must be in place in order to provide accountability for distributing external communications and creating transparency for the public.

Key Messages. Appropriate messages for different key audiences must be developed.

Vehicles and Materials. The appropriate materials and vehicles for delivery should be developed and determined for each key audience; there should also be an assessment of integration of those materials into the overall communications and transparency strategy.

Metrics of Success. In order to determine success, metrics for success (and success itself) should be clearly defined.




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Table 16 presents our assessment of the CFPB’s compliance with legal requirements. Each row in this table corresponds to a specific legal requirement. For each requirement, we describe the progress that the bureau has demonstrated to date, along with recommendations for future action. The bullets below highlight our key findings and recommendations

CFPB has complied with most requirements where we would expect to see progress in a bureau of this age. In particular, the CFPB has demonstrated exemplary progress in developing and implementing a process for complying with FOIA and has, in our judgment, appropriately complied with applicable laws governing this and other federal government agencies.

CFPB should continue to move toward filling positions and offices mandated by the Dodd-Frank Act. The Dodd-Frank Act mandated the creation of six offices that perform communications functions. The bureau is statutorily unable to create a Consumer Advisory Board (CAB) until a Director has been approved by Congress. However, a detailee is on staff currently serving in the Ombudsman role, which does not require a Director in place. In addition to filling the Ombudsman position with a permanent employee as soon as possible, we recommend that CFPB continue to move forward with developing plans for CAB and be prepared to staff positions as soon as a Director is approved.


Tables 17 through 21 present our assessment of the CFPB’s achievement of organizational goals. Each row in this table corresponds to a specific organizational goal. For each goal, we describe the progress that the bureau has demonstrated to date, along with recommendations for future action. The bullets below highlight our key findings and recommendations with regard to overall organizational goals and those specifically outlined by the CFPB 2011 Public Outreach Plan, the Office of Community Affairs, anecdotal discussions with the bureau’s stakeholders, and those outlined by CEE. Overall, CFPB Communications and Transparency stakeholders have demonstrated the appropriate levels of performance one would expect to see in a young organization.

CFPB has made a great deal of progress in achieving a number of its overall goals. In particular, the bureau as a whole has placed the utmost importance on engaging consumers, the general public, and consumer and civil rights advocacy groups; its efforts are evident (and successful) and should continue to drive the bureau going forward. Efforts could include, for example, continuing to think about and develop long-term ways to help consumers express the financial difficulties they face on an everyday basis. Finally, the CFPB should consider ways to publicly demonstrate its leadership in this area.

CFPB should further coordinate its mission, vision and values statements across mediums. Currently, the CFPB has defined its mission, vision and values, but they differ slightly across platforms. While slight variances are to be expected given the differing audiences each CFPB office is trying to reach (e.g., lawmakers, consumers and the general public), in places where the CFPB’s statutory purpose, mission, vision, and values are printed,


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it should consider reducing inconsistencies. Doing so will build brand strength over time and allow multiple audiences to fully understand how the CFPB views itself.

CFPB should use its overall strategy to develop coordinated strategies across divisions. The CFPB is in the process of developing a bureau-wide strategy document for the CFPB moving forward. We understand that individual divisions, (i.e., External Affairs, Consumer Engagement and Education, etc.), will use this plan to inform the plans of individual offices within the CFPB. This idea will help to formalize the continuity across divisions that already exists informally and will synchronize goals, plans and defined success.


Tables 22 through 27 present our assessment of the CFPB’s performance with respect to each of the six performance factors outlined in Section 5.2.3 (i.e., Goals and Objectives, Audiences, Policies and Processes, Strategies and Messages, Vehicles and Materials, and Metrics of Success). Each row in the tables corresponds to a goal, audience, policy, strategy, vehicle, or metric. For each, we provide the following information: (1) a rating of CFPB’s performance to date, using a stoplight scale (i.e., Red, Yellow or Green); (2) a summary of demonstrated performance; (3) the priority of future progress in this area, based on the importance of the performance area for a start-up organization; and (4) recommendations for future action. The bullets below highlight our key findings and recommendations. Key Findings

CFPB has made engaging the public its top priority. The CFPB as a whole has made substantial progress in communicating with and engaging the public, whether it is through digital mediums (e.g., the CFPB website and blog), events (e.g., townhall meetings, CFPB speeches), or one-on-one conversations. It is also clear that the CFPB has placed a high-level of importance on interacting with multiple audiences on a regular basis, including consumer groups, the private sector, policymakers, and the media. Internal documents reveal that the CFPB has gone to great lengths to meet with members of the private sector, particularly those that will be most affected by CFPB’s new authority, to keep them up to date on the direction the bureau is headed, and ask them for feedback.

CFPB has adopted and maintained a strong interest in being transparent and accountable to the public. This is something that, as many told us, has been baked into the organization since its inception. The transparency of the bureau was something former Special Advisor Elizabeth Warren strongly believed in, and is something that has translated to all aspects of the CFPB. The bureau is being transparent in numerous ways, including by posting the calendars of top officials on the website.

There is a strong “teamwork” mentality throughout the CFPB. In all of our discussions

with stakeholders, no individual in any division viewed his or her role as separate from the actions of other divisions. Part of what has made CFPB so successful to date, in our view, is the flow of information between offices and teams. For example, the Offices of Consumer Engagement and Education and External Affairs are constantly working together to determine


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how best to reach key audiences and how to share information across teams. Additionally, the Office of Servicemember Affairs is highly coordinated with other offices within CEE and External Affairs.

Nearest-Term Opportunities for Improvement (High Priority)

CFPB should continue work on developing additional language capabilities. The CFPB

has made efforts to engage populations that have been most severely impacted by the financial crisis. Currently the CFPB offers its 800 number in 189 languages, and is in the process of co-developing a Spanish version of the new single mortgage disclosure document from the Know Before You Owe initiative and a fully functional Spanish version of the website. Co-developing materials takes longer but it creates a much better product for consumers. CFPB should continue to move forward in developing additional language capabilities to allow all of its key constituencies to participate in the dialogue it is fostering.

CFPB should determine definitions of success. Defining success is always difficult,

particularly in communications. Often times there is no one number or metric that can be used to define success. While we understand the difficulty, offices within CFPB concerned with external communications should work together to develop documented definitions. Throughout our discussions with stakeholders, there were many times when the definition of success was simply understood. While this practice is useful internally, the CFPB would benefit greatly from putting agreed-upon definitions on paper. Doing so reinforces accountability and gives outsiders, including new staff, the ability to immediately understand what success looks like.

Mid-Term Opportunities for Improvement (Medium Priority)

CFPB should maintain policymaker interaction. Discussions with CFPB stakeholders

revealed a proactive view toward interacting with policymakers, including members of Congress, and state and local officials. Members of the CFPB team have testified before Congress on eleven occasions, have made numerous trips to the Hill to brief both Congressional staff and members of Congress, and regularly provide updates on news coming out of the bureau. CFPB should continue to engage policymakers and work toward establishing a two-way dialogue through which both the bureau and policymakers can gain important insight from one another.

CFPB should continue to engage key audiences. One of the challenges for the CFPB as it

continues to grow, mature and assume more responsibility is to continue the high level of engagement it has fostered thus far. The bureau has set a very high standard for itself and may encounter difficulties living up to that standard. An increase in staff will assist in meeting the growing responsibilities of the bureau.

Longer-Term Opportunities for Improvement (Low Priority)

CFPB should develop searchable content capability. One of Community Affairs’ goals is to have searchable resource content available for all reports, studies and communications with


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target groups. Community Affairs is currently working with the IT department to develop the digital infrastructure needed for such a resource. CFPB should continue to develop this capability.

CFPB should continue to develop internal processes. CFPB has implemented several internal processes, including a Clearance Memo that requires all external communications go through the Executive Secretary to ensure message continuity, a Media Memo that educates all CFPB staff on policies and procedures about dealing with the media, and multiple FOIA procedures that insure requests are responded to on time and that the appropriate people within CFPB are made aware of important requests. As discussed above, one of the challenges for CFPB moving forward will be maintaining the high level of performance the bureau has demonstrated to date. It will be important moving forward that all CFPB staff is properly educated on all internal processes and that the high level of performance continues. For example, as the CFPB continues to grow and assume more responsibility, there will undoubtedly be an increase in FOIA requests. Having a tight internal process in place (as CFPB does) will be imperative for high quality of performance to continue.

Feedback from External Stakeholders Melanie Pustay, Director of the Office of Information Policy (OIP), U.S. Department of Justice The CFPB’s policy towards FOIA was “impressive”, including its initiative when requesting a meeting with OIP to discuss the set up of its FOIA office. The request was “notable,” particularly because of how quick the inquiry was. Also impressive was the amount of thought CFPB representatives demonstrated throughout our discussion about FOIA. When the meeting ended, it was clear CFPB had thought of everything and that there were “no gaps.” Particularly impressive was CFPB’s enthusiasm for structuring an internal FOIA system that has the ability to take advantage of e-Discovery. A new technology, e-Discovery will bring instrumental change to the FOIA world as it will further facilitate document searches, and will de-duplicate documents electronically. Utilizing e-Discovery is a completely new idea, and the fact that CFPB was already thinking about its advantages and utilization demonstrated that the CFPB was “thinking outside the box.” It is very possible that CFPB’s attitudes towards and processes around FOIA could become the industry standard. As a new bureau opening its doors in the computer-age, CFPB has the unique opportunity to launch a system without the burden of trying to overhaul an entrenched, paper-based system. As CFPB continues to implement its eFOIA program, it will be one of the few agencies truly taking advantage of new technologies in this area. Melanie Pustay is the Director of the Office of Information Policy (OIP) at the U.S. Department of Justice (DOJ). OIP is the lead FOIA office for all of the federal government serving 97 different agencies; it disseminates the legal requirements around FOIA to those agencies and provides counsel on how to follow the Attorney General’s FOIA guidelines.


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Travis Plunkett, Legislative Director, Consumer Federation of America “It seems to have been a priority” for CFPB to engage with the financial industry, consumer and industry groups, and the public. CFPB has made an effort to be a transparent bureau, and in that sense, they “look to be functioning differently than most federal regulators.” Of particular note are the CFPB website and initial rulemaking efforts, which seem to be functioning in a more transparent manner. CFPB has tried to draw in audiences that are not typically involved in the rulemaking process, and has encouraged early input from these groups. CFPB began the process far ahead of its deadline and made a concerted effort to engage industry and consumer groups to get their thoughts. In the case of mortgage disclosure forms (i.e., Know Before You Owe), “I like the way they are reaching out to the public to see how [the revised documents] actually work.” The whole process of working with the public and interested parties is more open “and at least initially, more promising” in terms of engaging the public. The CFPB’s website, is like “no other federal government website I’ve seen,” as are the reports on credit scores and remittances the CFPB issued. Both reports are “well done,” and it is refreshing that financial jargon is not used, particularly because they are aimed at reaching a general consumer audience. Though the CFPB is still new, very soon it will need to move beyond the general categories of issues it is discussing and start addressing specific issues they have identified as important, based on discussions with industry, consumer and public discussions. Also, regardless of the political climate, CFPB needs to continue to focus on what it can do—not what it can’t do—because it still has a great deal of authority even without a Director in place. Travis Plunkett is the Legislative Director for the Consumer Federation of America. Select Members of the Press The following is a compilation of “not-for-attribution” conversations had with several members of the press about the CFPB regarding its efforts around communications and transparency. While most consumers don’t follow the actions of federal agencies, the CFPB has a unique mandate in that it is a consumer-oriented bureau. Given that, the expectations related to reaching the public are different, and the CFPB’s name recognition among consumers is still very limited. Considering the age of the bureau and its limited staff, CFPB has done a good of job getting the message out regarding its mission and how it intends to serve the public interest. Its message is very proactive and consistent, and it invites the public to participate and provide information. The CFPB’s website is good, easy to navigate and consumer friendly. CFPB has fully embraced transparency, as evidenced by its near-real-time posting of schedules for senior officials on the CFPB website, with few redactions. As compared to other federal agencies, CFPB is more proactive in this area. CFPB has also been very public about meetings it has held with industry and consumer groups, and on FOIA requests, it has been very responsive. Too often, CFPB and other federal agencies provide interviews on background (i.e., the reporter cannot use any quotes


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from the discussion in his/her reporting), then provide written quotes after the interview. This occurs even when the discussion topic does not warrant such an approach. The Dodd-Frank Act—and by extension, CFPB—has been a subject of great debate in Washington. As such, it is important for the Bureau to be transparent and avoid major missteps. CFPB is still in the process of collecting data so it remains to be seen how it will utilize the information it gathers to aid its regulatory function, but if it continues the trend it has established so far, the bureau will be successful. Case Studies The following case studies are summaries of actions within the CFPB that we felt warranted special recognition as practices that demonstrate how the CFPB works to fulfill its mandate. They are based on conversations with staff and verified in documents provided. Community Affairs Situation: Congress charged the CFPB with addressing issues that are most fundamental to consumers’ everyday lives. The challenges the CFPB faced include determining how best to reach consumers to understand what issues are most important to them and how to create a feedback loop between the bureau and consumers. Action: CFPB developed a working relationship with the advocacy group Americans for Financial Reform (AFR) that included regular communications, meetings and joint efforts. The CFPB worked with AFR to understand key issues and held regular forums with subject matter experts to discuss those key issues. Additionally, CFPB worked directly with AFR to identify grassroots organizations on the ground that could serve as conduits for the delivery of CFPB’s financial services. Results: Through the working relationship with AFR, the CFPB was able to create a conduit to consumers and a feedback loop between itself and consumers. CFPB has met with numerous AFR working groups on topics including consumer response, new media, research and data collection, and mortgages. Doing so has provided invaluable resources, data and assistance, particularly leading up to the establishment of CFPB’s own consumer response system. Regular meetings with AFR working groups allows CFPB subject matter experts to have access to external sources of information that become part of internal discussions across the bureau. Small Business, Community Banks & Credit Unions Situation: When CFPB began its work, the bureau recognized the need to develop a feedback loop between itself and the institutions it would supervise and provide rules for (i.e., large banks and community banks and credit unions, respectively). The challenge was not necessarily getting CFPB’s voice to the institutions, but rather creating a way to hear from them. Action: CFPB recognized the difficulty associated with trying to engage each and every community bank and consumer union across the country. CFPB made the decision that in addition to direct outreach, it would work through trade associations. One such association was the Independent Community Bankers of America (ICBA).


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Results: Through its relationship with trade associations like ICBA, CFPB was able to receive consistent flows of information on community banks’ feelings on current and future CFPB initiatives. CFPB’s relationship with ICBA also helped it reach its ambitious goal of meeting with community bankers from all 50 states in less than a year.

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Ser

vicem

embe

r Affa

irs.

A ke

y ob

ject

ive fo

r the

Offic

e as

del

inea

ted

in th

e st

atut

e is

to “e

duca

te a

nd e

mpo

wer s

ervic

emem

bers

an

d th

eir f

amilie

s to

mak

e be

tter i

nfor

med

dec

ision

s re

gard

ing

cons

umer

fin

ancia

l pro

duct

s an

d se

rvice

s”.

• CF

PB h

as c

reat

ed th

e O

ffice

of

Serv

icem

embe

r Affa

irs.

• In

our

judg

men

t, ba

sed

on th

e in

form

atio

n pr

ovid

ed, t

he

CFPB

has

met

its o

blig

atio

ns in

this

area

.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

78

Lega

l Req

uire

men

t De

mon

stra

ted

Perfo

rman

ce

Find

ing

/ Rec

omm

enda

tion

CFPB

is re

quire

d by

Title

10,

Sec

tion

1013

(g) o

f the

Dod

d-Fr

ank

Act t

o cr

eate

the

Offic

e of

Fin

ancia

l Pro

tect

ion

for O

lder

Am

erica

ns, d

efin

ed a

s in

divid

uals

62 y

ears

or o

lder

. Th

e go

al fo

r thi

s of

fice

is to

est

ablis

h pr

ogra

ms

that

pro

vide

finan

cial li

tera

cy a

nd c

ouns

elin

g an

d to

wor

k wi

th

othe

r com

mun

ity a

nd n

on-p

rofit

orga

niza

tions

that

ass

ist s

enio

rs

• As

out

lined

in D

odd-

Fran

k, C

FPB

is no

t re

quire

d to

hav

e cr

eate

d th

e O

ffice

of

Fina

ncia

l Pro

tect

ion

for O

lder

Am

erica

ns u

ntil

Janu

ary

21, 2

012.

Alth

ough

the

Offic

e of

Fi

nanc

ial P

rote

ctio

n fo

r Old

er A

mer

icans

is

not e

valu

ated

in th

is re

port,

sin

ce th

e O

ffice

was

crea

ted

on A

ugus

t 28,

the

actin

g di

rect

or

of th

e O

ffice

met

with

num

erou

s go

vern

men

tal o

ffices

and

sta

keho

lder

s in

volve

d in

issu

es a

ffect

ing

Old

er A

mer

icans

, co

nsist

ent w

ith C

FPB’

s st

atut

ory

man

date

. Th

e pe

rman

ent A

ssist

ant D

irect

or w

ill be

on

boar

d on

Oct

ober

17.

• In

our

judg

men

t, ba

sed

on th

e in

form

atio

n pr

ovid

ed, t

he

CFPB

has

met

its o

blig

atio

ns in

this

area

.

CFPB

is re

quire

d by

Title

10,

Sec

tion

1035

of t

he D

odd-

Fran

k Ac

t to

desig

nate

a P

rivat

e Ed

ucat

ion

Loan

Om

buds

man

. In

clude

d in

the

dutie

s pr

escr

ibed

for t

he O

mbu

dsm

an is

a c

harg

e to

“ens

ure

coor

dina

tion

in

prov

idin

g as

sista

nce

to a

nd s

ervin

g bo

rrowe

rs s

eekin

g to

reso

lve

com

plai

nts

rela

ted

to th

eir p

rivat

e ed

ucat

ion

or F

eder

al s

tude

nt lo

ans”

.

• As

out

lined

in th

e Do

dd-F

rank

Act

, CFP

B is

not r

equi

red

to h

ave

desig

nate

d a

Priva

te

Educ

atio

n Lo

an O

mbu

dsm

an u

ntil O

ctob

er

21, 2

011.

Give

n th

at, t

he fu

nctio

n of

Priv

ate

Educ

atio

n Lo

an O

mbu

dsm

an is

not

ev

alua

ted

in th

e re

mai

nder

of t

his

repo

rt.

• De

signa

te a

Priv

ate

Educ

atio

n Lo

an O

mbu

dsm

an b

y th

e da

te p

resc

ribed

in D

odd-

Fran

k.

CFPB

is re

quire

d by

Title

10,

Sec

tion

1013

(d) o

f the

Dod

d-Fr

ank

Act t

o es

tabl

ish th

e O

ffice

of F

inan

cial E

duca

tion,

whi

ch is

resp

onsib

le fo

r ed

ucat

ing

cons

umer

s to

hel

p th

em m

ake

bette

r fin

ancia

l dec

ision

s. T

his

offic

e is

char

ged

to re

ach

out d

irect

ly to

con

sum

ers

and

to c

oord

inat

e wi

th

othe

r offic

es w

ithin

CFP

B to

car

ry o

ut its

man

date

s.

• CF

PB h

as c

reat

ed th

e O

ffice

of F

inan

cial

Educ

atio

n. H

owev

er, d

ue to

the

newn

ess

of

the

offic

e at

this

time,

it is

not e

valu

ated

in th

e re

mai

nder

of t

his

repo

rt.

• In

our

judg

men

t, ba

sed

on th

e in

form

atio

n pr

ovid

ed, t

he

CFPB

has

met

its o

blig

atio

ns in

this

area

.

CFPB

is re

quire

d to

com

ply

with

the

Free

dom

of I

nfor

mat

ion

Act (

FOIA

). FO

IA p

rovid

es a

ll citiz

ens

with

the

right

of a

cces

s to

fede

ral a

genc

y re

cord

s or

info

rmat

ion.

Whe

n a

writte

n re

ques

t for

info

rmat

ion

is re

ceive

d by

a

fede

ral a

genc

y, th

e ag

ency

is re

quire

d to

disc

lose

thos

e re

cord

s, u

nles

s th

ey c

an b

e la

wful

ly wi

thhe

ld u

nder

nin

e sp

ecific

exe

mpt

ions

out

lined

in th

e st

atut

e. T

he b

urde

n is

on th

e go

vern

men

t, no

t the

pub

lic, t

o pr

ovid

e ex

plan

atio

n fo

r why

info

rmat

ion

cann

ot b

e re

leas

ed.

• Th

e FO

IA M

anag

er p

ositio

n ha

s be

en fil

led

with

in th

e O

ffice

of R

ecor

ds, P

rivac

y an

d FO

IA.

• Th

e CF

PB is

alre

ady

rece

iving

and

re

spon

ding

to F

OIA

requ

ests

.

• FO

IA is

a k

ey c

ompo

nent

to th

e CF

PB b

eing

tran

spar

ent

with

the

publ

ic. It

has

a p

lan

in p

lace

that

it is

impl

emen

ting

to re

spon

d to

requ

ests

. The

laun

ch o

f the

eF

OIA

sys

tem

, whi

ch is

cur

rent

ly in

the

pilo

t pha

se, w

ill ex

ceed

wha

t the

law

requ

ires

of th

e CF

PB in

this

area

.

• In

our

judg

men

t, ba

sed

on th

e in

form

atio

n pr

ovid

ed, t

he

CFPB

has

met

its o

blig

atio

ns in

this

area

.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

79

Lega

l Req

uire

men

t De

mon

stra

ted

Perfo

rman

ce

Find

ing

/ Rec

omm

enda

tion

CFPB

is re

quire

d to

com

ply

with

the

E-G

over

nmen

t Act

of 2

002.

The

E-

Gov

ernm

ent A

ct o

f 200

2's p

urpo

se is

to im

prov

e el

ectro

nic

gove

rnm

ent

serv

ices

by e

stab

lishi

ng a

Fed

eral

Chi

ef T

echn

olog

y O

fficer

, loca

ted

in th

e O

ffice

of M

anag

emen

t and

Bud

get,

and

crea

ting

a fra

mew

ork

that

requ

ires

Inte

rnet

-bas

ed in

form

atio

n te

chno

logy

to im

prov

e th

e tra

nspa

renc

y of

and

ac

cess

to g

over

nmen

t info

rmat

ion

and

serv

ices

for c

itizen

s. T

he s

tatu

te

inclu

des

the

Fede

ral In

form

atio

n Se

curit

y M

anag

emen

t Act

of 2

002

(FIS

MA)

and

the

Conf

iden

tial In

form

atio

n Pr

otec

tion

and

Stat

istica

l Ef

ficie

ncy

Act (

CIPS

EA).

• Th

e CF

PB h

as d

evel

oped

and

impl

emen

ted

an IT

stru

ctur

e th

at a

dher

es to

the

E-G

over

nmen

t Act

, inclu

ding

FIS

MA.

• In

our

judg

men

t, ba

sed

on th

e in

form

atio

n pr

ovid

ed, t

he

CFPB

has

met

its o

blig

atio

ns in

this

area

.

CFPB

is re

quire

d to

com

ply

with

the

Fede

ral F

undi

ng a

nd A

ccou

ntab

ility

Tran

spar

ency

Act

(FFA

TA).

FFAT

A re

quire

s th

at a

ll ent

ities

or

orga

niza

tions

rece

iving

fede

ral fu

nds

as o

f FY

2007

are

disc

lose

d to

the

publ

ic, w

ith th

e in

tent

to e

mpo

wer a

ll citiz

ens

with

the

abilit

y to

hol

d th

e go

vern

men

t acc

ount

able

for s

pend

ing

decis

ions

. Al

l info

rmat

ion

on fe

dera

l aw

ards

are

ava

ilabl

e to

the

publ

ic via

www

.usa

spen

ding

.gov

, pro

vidin

g tra

nspa

rent

info

rmat

ion

to th

e pu

blic

on g

over

nmen

t spe

ndin

g de

cisio

ns.

• Th

e CF

PB p

osts

awa

rded

fede

ral c

ontra

cts

to its

web

site.

•

In o

ur ju

dgm

ent,

base

d on

the

info

rmat

ion

prov

ided

, the

CF

PB h

as m

et its

obl

igat

ions

in th

is ar

ea.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

80

Tab

le 1

7: A

chie

vem

ent

of O

rgan

izat

ion

al G

oals

(O

vera

ll S

trat

egie

s)

Org

aniz

atio

nal G

oal

Dem

onst

rate

d Pe

rform

ance

Fi

ndin

g / R

ecom

men

datio

n

Build

fam

iliarit

y wi

th th

e CF

PB b

rand

• La

stin

g br

and

fam

iliarit

y is

ofte

n ac

hiev

ed b

y go

ing

to w

here

peo

ple

are.

The

CF

PB h

as p

ositio

ned

itsel

f to

achi

eve

bran

d fa

milia

rity

by d

evel

opin

g a

good

we

b pr

esen

ce, b

uild

ing

rela

tions

hips

with

key

sta

keho

lder

s, s

truct

urin

g ke

y di

visio

ns in

the

man

ner m

ost a

cces

sible

to th

e CF

PB’s

key

audi

ence

(c

onsu

mer

s), a

nd u

sing

the

med

ia a

s a

vehi

cle to

rein

forc

e its

bra

nd.

• W

hile

the

CFPB

has

dem

onst

rate

d th

at a

gre

at d

eal o

f th

ough

t has

gon

e in

to its

bra

nd, o

ne c

once

rn is

that

the

CFPB

def

ines

its m

issio

n di

ffere

ntly

in d

iffere

nt p

lace

s.

And

while

it’s

unde

rsta

ndab

le to

a d

egre

e th

at th

e CF

PB w

ould

wan

t to

mak

e its

sta

ted

miss

ion

easy

to

unde

rsta

nd, s

trict

lang

uage

gui

delin

es p

erta

inin

g to

m

anda

te, m

issio

n, a

nd v

ision

will

help

bra

nd s

treng

th

over

time.

• Th

us, w

e re

com

men

d th

e CF

PB re

visit t

he th

ree

area

s it h

as p

ublic

ly co

mm

unica

ted

in p

rint it

s m

anda

te,

miss

ion,

visi

on a

nd v

alue

s an

d m

ake

effo

rts to

redu

ce

the

varia

nces

and

rem

ain

as c

onsis

tent

as

poss

ible

ac

ross

all m

ediu

ms.

Enga

ge th

e pu

blic

•

Mon

thly

even

ts o

utsid

e of

Was

hing

ton,

DC

to in

trodu

ce C

FPB

and

anno

unce

key

pol

icy d

elive

rabl

es w

ith a

n op

portu

nity

for f

eedb

ack

via

town

halls

, rou

ndta

bles

, wor

ksho

ps, e

tc.

• Th

e CF

PB h

as d

one

a gr

eat d

eal o

f wor

k to

eng

age

the

publ

ic an

d ha

s be

en c

reat

ive in

doi

ng s

o (s

omet

hing

not

ofte

n fo

und

in fe

dera

l age

ncie

s),

inclu

ding

by

sele

ctin

g ev

ent t

opics

bas

ed o

n im

porta

nt

date

s an

d iss

ues

so th

at th

ere

mig

ht b

e an

inhe

rent

pu

blic

inte

rest

in th

e to

pic

(i.e.

, less

ons

lear

ned

from

th

e fin

ancia

l cris

is –

Sept

embe

r 15)

.

Expl

ain

polic

y de

liver

able

s in

pla

in E

nglis

h

• Th

e we

bsite

was

dev

elop

ed w

ith a

n 8th

gra

de re

ader

in m

ind.

•

Gat

herin

g fe

edba

ck th

roug

h to

wn h

alls

and

cons

umer

eve

nts

allo

w th

e CF

PB to

“get

out

of t

he b

ubbl

e” a

nd d

eter

min

e wh

at c

onsu

mer

s ne

ed.

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce

elem

ent

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

81

Org

aniz

atio

nal G

oal

Dem

onst

rate

d Pe

rform

ance

Fi

ndin

g / R

ecom

men

datio

n

Illust

rate

the

cons

umer

impa

ct

• M

onth

ly ev

ents

like

thos

e di

scus

sed

abov

e ge

nera

te c

onsu

mer

sto

ries

that

he

lp ill

ustra

te th

e iss

ues

cons

umer

s ar

e fa

cing.

•

The

focu

s on

“poc

ketb

ook”

issu

es (i

ssue

s wi

th d

irect

rele

vanc

e to

the

ever

yday

lives

of A

mer

ican

fam

ilies

and

thei

r fin

ance

s) re

info

rce

that

the

CFPB

und

erst

ands

wha

t con

sum

ers

valu

e m

ost.

• Th

e in

clusio

n of

the

thre

e cr

iteria

that

poc

ketb

ook

polic

y de

liver

able

s ne

ed to

mee

t in o

rder

to m

axim

ize

natio

nal a

nd lo

cal a

ttent

ion

is an

exc

elle

nt s

trate

gy.

Also

a re

cent

op-

ed a

rticu

latin

g th

e im

pact

of t

he 9

0/10

ru

le in

the

for-p

rofit

educ

atio

n se

ctor

on

serv

icem

embe

rs is

a g

ood

exam

ple

of h

ow to

hig

hlig

ht

the

impa

ct o

f cer

tain

pol

icies

on

cons

umer

s.

• W

e re

com

men

d co

ntin

uing

to lo

ok fo

r cre

ative

way

s to

he

lp c

onsu

mer

s ex

pres

s th

e ch

alle

nges

they

face

and

th

eir p

erso

nal e

xper

ienc

es. D

oing

this

succ

essf

ully

will

be c

entra

l to th

e lo

ng-te

rm s

ucce

ss o

f the

CFP

B an

d wi

ll allo

w CF

PB to

dev

elop

fact

-bas

ed w

ays

to e

xpla

in

issue

s to

oth

er c

onsu

mer

s.

Max

imize

bur

eau

reso

urce

s

• W

hen

the

CFPB

con

vene

s ev

ents

aro

und

the

coun

try, it

see

ks to

take

ad

vant

age

of h

avin

g st

aff a

nd s

take

hold

ers

toge

ther

in th

at lo

catio

n (e

.g.,

arou

nd th

e Ph

ilade

lphi

a ev

ent o

n 9/

15, C

FPB

staf

f met

with

com

mun

ity

grou

ps fo

llowi

ng th

e pr

ess

even

t).

• In

divid

ual o

ffices

acr

oss

all d

ivisio

ns o

f CFP

B ar

e co

mm

itted

to w

orkin

g wi

th

othe

r tea

ms

and

help

ing

othe

r offic

es fu

lfill th

eir s

tatu

tory

out

reac

h m

anda

te

(e.g

., Co

mm

unity

Affa

irs p

rovid

ing

outre

ach

supp

ort a

t the

Phi

lade

lphi

a ev

ent o

n 9/

15).

• Th

e CF

PB h

as m

ade

a co

ncer

ted

effo

rt to

max

imize

re

sour

ces

and

acco

mpl

ished

a g

reat

dea

l with

limite

d st

aff in

par

t bec

ause

of it

s co

mm

itmen

t to

do s

o.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

82

Tab

le 1

8: A

chie

vem

ent

of O

rgan

izat

ion

al G

oals

(C

omm

uni

ty A

ffai

rs S

trat

egie

s)

Org

aniz

atio

nal G

oal

Dem

onst

rate

d Pe

rform

ance

Fi

ndin

g / R

ecom

men

datio

n

Touc

h m

ost s

igni

fican

t nat

iona

l and

regi

onal

con

sum

er, c

ivil r

ight

s, a

nd

gras

sroo

ts a

dvoc

acy

orga

niza

tions

in th

e fin

ancia

l ser

vices

spa

ce

(~20

0).

• O

ver t

he p

ast y

ear,

CFPB

has

hel

d ne

arly

250

mee

tings

wi

th g

roup

s in

cludi

ng A

ARP,

AFR

, You

th, N

CLR,

Lat

ino

grou

ps, N

AACP

, con

sum

er g

roup

s, c

ivil r

ight

s gr

oups

, fa

ith g

roup

s, e

tc.

• G

iven

how

signi

fican

t the

effo

rts h

ave

been

to

enga

ge c

omm

unity

gro

ups,

a tr

acke

r to

orga

nize

the

CFPB

’s ef

forts

in th

is ar

ea w

ill he

lp

it tel

l its

stor

y of

who

it is

reac

hing

and

how

it is

reac

hing

them

. The

trac

ker c

ould

inclu

de a

list

of g

roup

s th

e CF

PB h

as e

ngag

ed, t

he la

st p

oint

of

con

tact

, nat

ure

of th

e co

ntac

t, ne

xt s

teps

to

furth

er e

ngag

e th

e or

gani

zatio

n, a

nd p

erha

ps

som

e as

sess

men

t of t

he d

egre

e to

whi

ch th

at

orga

niza

tion

is cu

rrent

ly en

gage

d.

Deve

lop

“ear

ly wa

rnin

g” in

form

atio

n fro

m th

e fie

ld a

nd m

ake

avai

labl

e to

al

l CFP

B re

ports

and

stu

dies

from

con

sum

er, c

ivil r

ight

s, a

nd c

omm

unity

gr

oups

abo

ut im

pact

s of

spe

cific

finan

cial s

ervic

e pr

oduc

ts a

nd p

ract

ices

on n

eigh

borh

oods

and

com

mun

ities.

• Th

e m

eetin

gs m

entio

ned

abov

e as

wel

l as

roun

dtab

le

disc

ussio

ns th

e CF

PB h

olds

, ofte

n in

con

junc

tion

with

a

larg

er C

FPB-

host

ed e

vent

(e.g

., Ph

ilade

lphi

a on

9/1

5/11

) se

rve

as p

roac

tive

solic

itatio

ns fo

r fee

dbac

k fro

m th

e “fi

eld”

. In

addi

tion,

the

rela

tions

hips

dev

elop

ed w

ith th

e gr

oups

out

lined

abo

ve c

reat

e a

feed

back

loop

so

that

th

ose

grou

ps h

ave

acce

ss to

the

CFPB

to s

hare

in

form

atio

n.

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce e

lem

ent

Crea

te s

earc

habl

e co

nten

t res

ourc

e of

thos

e re

ports

and

stu

dies

, and

pr

ovid

e pe

riodi

c up

date

s fo

r all C

FPB

staf

f of t

he in

put r

ecei

ved

from

th

ese

grou

ps.

• W

hile

the

CFPB

is in

the

proc

ess

of d

evel

opin

g th

e se

arch

able

con

tent

reso

urce

, as

soon

as

Cons

umer

Af

fairs

get

s re

ports

(int

erna

l and

ext

erna

l), th

ey s

hare

ex

cerp

ts a

nd k

ey p

oint

s wi

th o

ther

CFP

B st

aff.

• Th

e co

mpl

ete

deve

lopm

ent o

f a s

earc

habl

e co

nten

t res

ourc

e wi

ll be

a te

rrific

way

to s

hare

in

form

atio

n an

d m

axim

ize b

urea

u re

sour

ces.

Be a

reso

urce

to c

onsu

mer

, civi

l rig

hts

and

nonp

rofit

orga

niza

tions

, and

he

lp a

ll par

ts o

f the

CFP

B ac

cess

kno

wled

ge a

nd in

form

atio

n fro

m th

ose

grou

ps.

• Ro

undt

able

s he

ld b

y th

e CF

PB b

ring

toge

ther

co

nstitu

ency

gro

ups,

inclu

ding

old

er A

mer

icans

, stu

dent

s an

d m

inor

ity g

roup

s to

cre

ate

a tw

o-wa

y di

alog

ue.

• An

inte

rnal

wee

kly lo

ok-a

-hea

d do

cum

ent is

pro

vided

to

all C

FPB

pers

onne

l so

they

can

see

upc

omin

g ex

tern

al

mee

tings

takin

g pl

ace

in th

e ev

ent it

mak

es s

ense

for

othe

r gro

ups

with

in C

FPB

to p

artic

ipat

e.

• Ad

ditio

nal r

esou

rces

inclu

de: s

ocia

l med

ia, t

he w

ebsit

e an

d th

e 80

0 nu

mbe

r.

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce e

lem

ent

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

83

Tab

le 1

9: A

chie

vem

ent

of O

rgan

izat

ion

al G

oals

(A

nec

dot

al G

oals

)

Org

aniz

atio

nal G

oal

Dem

onst

rate

d Pe

rform

ance

Fi

ndin

g / R

ecom

men

datio

n

Adhe

re to

all a

ppro

pria

te fe

dera

l man

date

s

• Th

e CF

PB a

dher

es to

the

Dodd

-Fra

nk A

ct, F

OIA

, FF

ATA,

and

the

e-G

over

nmen

t Act

.

• In

our

judg

men

t, ba

sed

on th

e in

form

atio

n pr

ovid

ed, t

he C

FPB

has

met

its o

blig

atio

ns in

th

is ar

ea. A

s m

entio

ned

in T

able

18,

whi

le th

e ro

le o

f the

Om

buds

man

is fil

led

with

a d

etai

lee,

it do

es n

ot h

ave

a fu

ll-tim

e pe

rman

ent e

mpl

oyee

fill

ing

the

posit

ion.

We

reco

mm

end

doin

g so

as

soon

as

poss

ible

.

Mai

ntai

n th

e sp

irit o

f tra

nspa

renc

y th

at w

as “b

aked

into

the

orga

niza

tion”

at

its in

cept

ion

• Th

e CF

PB m

ade

both

Eliz

abet

h W

arre

n an

d Ra

j Dat

e’s

sche

dule

pub

lic o

n th

e we

bsite

. •

The

CFPB

has

a p

roac

tive,

forw

ard-

look

ing

FOIA

op

erat

ion

in p

lace

. •

Ever

yone

we

inte

rvie

wed

took

tran

spar

ency

and

ac

coun

tabi

lity v

ery

serio

usly.

• W

e re

com

men

d th

e CF

PB c

ontin

ue its

effo

rts

arou

nd tr

ansp

aren

cy a

nd c

ontin

ue to

find

new

ways

to d

emon

stra

te its

com

mitm

ent in

this

area

. Ide

as in

clude

: mak

ing

agen

das

and

min

utes

from

pub

lic a

nd in

tern

al m

eetin

gs

avai

labl

e.

Educ

ate

the

publ

ic on

wha

t CFP

B is

and

what

it is

doin

g to

hel

p or

dina

ry

Amer

icans

• Th

e CF

PB c

reat

ed a

web

site

that

is e

asy

to n

avig

ate

and

unde

rsta

nd a

nd u

ses

it as

a ve

hicle

to e

ngag

e co

nsum

ers,

inclu

ding

see

king

and

impl

emen

ting

thei

r fe

edba

ck.

• Th

e CF

PB h

as m

ade

a co

ncer

ted

effo

rt to

go

to w

here

th

e pu

blic

is by

cre

atin

g th

e O

ffice

of E

ngag

emen

t and

ho

ldin

g ev

ents

with

con

sum

er g

roup

s ac

ross

the

coun

try.

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce e

lem

ent

Mee

t with

com

mun

ity b

anke

rs fr

om a

ll 50

stat

es

• Th

e CF

PB a

chie

ved

this

goal

ahe

ad o

f sch

edul

e.

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce e

lem

ent

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

84

Tab

le 2

0: A

chie

vem

ent

of O

rgan

izat

ion

al G

oals

(C

onsu

mer

En

gage

men

t)

Org

aniz

atio

nal G

oal

Dem

onst

rate

d Pe

rform

ance

Fi

ndin

g / R

ecom

men

datio

n

CFPB

-wid

e sh

ared

visi

on o

f the

role

of

enga

gem

ent a

nd th

e de

sired

impa

ct o

n th

e pu

blic

of o

ur e

ngag

emen

t wor

k

• CE

E ha

s m

et w

ith a

ll of it

s in

tern

al d

ivisio

ns (i

.e.,

Cons

umer

Eng

agem

ent,

OSA

, etc

.), a

nd m

any

publ

ic-fa

cing

divis

ions

, (i.e

., Ex

tern

al A

ffairs

, Med

ia

Rela

tions

), to

cre

ate

a sh

ared

visi

on a

s se

rvice

pro

vider

s fo

r dig

ital a

nd n

on-

digi

tal e

ngag

emen

t cam

paig

ns a

cros

s th

e CF

PB.

• CE

E ha

s al

so m

et w

ith C

FPB

lead

ersh

ip to

disc

uss

a go

vern

ance

stru

ctur

e fo

r th

e CF

PB’s

curre

nt d

igita

l offe

rings

and

wor

k on

long

-term

visi

ons

for t

he

offe

rings

. •

Two

work

ing

sess

ions

hav

e ta

ken

plac

e to

def

ine

CEE’

s m

issio

n an

d vis

ion;

to

date

, a d

raft

miss

ion

has

been

dev

elop

ed.

• Co

nsum

er E

ngag

emen

t sho

uld

cont

inue

to

work

on

defin

ing

its o

wn m

issio

n an

d vis

ion,

en

surin

g th

at th

ey a

re in

agr

eem

ent w

ith th

e m

issio

n an

d vis

ion

of th

e CF

PB a

s a

whol

e.

Deve

lopi

ng s

pecif

ic ob

ject

ives

for e

ach

offic

e wi

thin

the

CFPB

mak

es s

ense

, but

it is

very

im

porta

nt th

at th

ose

obje

ctive

s al

ign

with

the

over

all m

issio

n of

the

CFPB

.

Org

aniza

tiona

l stru

ctur

e, p

ositio

n de

scrip

tions

, ca

reer

ladd

ers,

recr

uitm

ent p

lan,

and

pol

icies

to

supp

ort t

he w

ork

(exa

mpl

e, “b

log

on o

ther

site

s”

polic

y)

• CE

E ha

s fo

cuse

d its

effo

rts o

n de

velo

ping

cur

rent

per

sonn

el in

Con

sum

er

Enga

gem

ent a

nd d

oubl

ing

the

size

of th

e of

fice

(exc

ludi

ng le

ader

ship

) fro

m

two

to fo

ur b

y 2Q

201

2.

• Po

sitio

n de

scrip

tions

and

car

eer l

adde

rs fo

r the

se n

ew p

ositio

ns a

re e

ither

in

plac

e or

in d

evel

opm

ent.

• CE

E ha

s de

cided

to d

efer

furth

er re

crui

ting

effo

rts u

ntil 2

Q 2

012

in o

rder

to

take

adv

anta

ge o

f a b

ette

r-exp

ecte

d re

crui

ting

envir

onm

ent.

• CE

E ha

s id

entifi

ed a

num

ber o

f are

as o

f dev

elop

men

t tha

t dee

m d

iscus

sion,

th

ough

no

subs

tant

ive d

evel

opm

ent h

as ta

ken

plac

e ye

t. •

The

orga

niza

tiona

l cha

rt ha

s un

derg

one

a nu

mbe

r of e

dits

sin

ce J

uly,

with

ap

prop

riate

cha

nges

with

in C

EE re

flect

ed.

• Co

nsum

er E

ngag

emen

t sho

uld

mov

e qu

ickly

to

fill o

ut th

e of

fice

and

deve

lop

the

appr

opria

te

plan

s an

d po

licie

s to

allo

w it t

o ef

fect

ively

oper

ate.

Blue

prin

t for

the

CFPB

“con

sum

er e

xper

ienc

e,”

conc

epts

for C

FPB

prod

uct a

nd s

ervic

e of

ferin

gs

such

as

inte

ract

ive to

ols,

plu

s pl

an w

ith tim

elin

e to

br

ing

one

or m

ore

of th

ose

mor

e sig

nific

ant t

ools

to

fruitio

n

• Co

nsum

er E

ngag

emen

t is w

orkin

g wi

th a

n ou

tsid

e co

ntra

ctor

to d

evel

op a

dr

aft b

luep

rint f

or th

e CF

PB c

onsu

mer

exp

erie

nce;

the

blue

prin

t will

be

pres

ente

d to

CFP

B le

ader

ship

the

week

of O

ctob

er 1

0th.

• Fi

nal s

ign-

off is

exp

ecte

d in

mid

-Nov

embe

r, on

trac

k fo

r a fin

al d

elive

ry o

f De

cem

ber 2

011.

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce e

lem

ent

IT s

olut

ion

for e

dito

rial w

orkf

low

and

cont

ent

man

agem

ent s

yste

m fo

r Con

sum

erFi

nanc

e.go

v

• Co

nsum

er E

ngag

emen

t has

col

labo

rate

d wi

th C

FPB’

s te

chno

logy

and

in

form

atio

n of

fices

and

requ

este

d th

e ne

cess

ary

budg

et a

nd p

erso

nnel

for t

his

proj

ect.

• Co

nsum

er E

ngag

emen

t exp

ects

this

proj

ect t

o be

gin

durin

g 2Q

201

2, th

ough

di

scus

sions

are

alre

ady

unde

rway

to d

eter

min

e th

e pr

ojec

t’s s

cope

, re

quire

men

ts a

nd tim

elin

e.

• W

e re

com

men

d Co

nsum

er E

ngag

emen

t co

ntin

ue to

wor

k th

e te

chno

logy

and

info

rmat

ion

offic

es w

ithin

CFP

B to

dev

elop

the

scop

e,

requ

irem

ents

and

timel

ine

of th

e pr

ojec

t.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

85

Org

aniz

atio

nal G

oal

Dem

onst

rate

d Pe

rform

ance

Fi

ndin

g / R

ecom

men

datio

n

Impr

oved

bus

ines

s pr

oces

s fo

r gen

erat

ing

and

clear

ing

cont

ent f

or u

se o

n ou

r web

site

and

othe

r el

ectro

nic

chan

nels

• Du

e to

the

CFPB

-wid

e st

rate

gy p

roce

ss, w

hich

has

iden

tified

the

clear

ance

pr

oces

s as

a p

ossib

le a

rea

for i

mpr

ovem

ent,

Cons

umer

Eng

agem

ent h

as

defe

rred

work

on

an im

prov

ed b

usin

ess

proc

ess

for g

ener

atin

g an

d cle

arin

g co

nten

t for

web

site

and

elec

troni

c us

e.

• If

the

clear

ance

pro

cess

is d

eter

min

ed a

s an

are

a fo

r im

prov

emen

t, Co

nsum

er

Enga

gem

ent p

lans

to in

volve

itsel

f in th

e ne

w po

licy

deve

lopm

ent p

roce

ss.

• If

the

clear

ance

pro

cess

is no

t det

erm

ined

as

an a

rea

for i

mpr

ovem

ent,

the

Cons

umer

Eng

agem

ent w

ill m

ove

forw

ard

with

impr

ovin

g th

e pr

oces

s al

read

y in

pla

ce.

• If

it is

dete

rmin

ed th

at th

e Cl

eara

nce

Proc

ess

is in

nee

d of

impr

ovem

ent,

we re

com

men

d co

nsid

erat

ions

for a

mor

e st

ream

lined

app

roac

h an

d st

rong

ly en

cour

age

Cons

umer

En

gage

men

t to

be in

volve

d in

the

proc

ess

of

deve

lopi

ng a

new

pol

icy.

8-10

blo

g po

sts

each

mon

th g

ener

ated

by

the

Enga

gem

ent O

ffice,

plu

s su

ppor

t for

finan

cial

educ

atio

n co

nten

t in p

ost a

nd tip

form

gen

erat

ed b

y th

e O

FE (i

n ad

ditio

n to

pos

ts fr

om a

roun

d th

e bu

reau

)

• Co

nsum

er E

ngag

emen

t has

con

siste

ntly

work

ed w

ith a

num

ber o

f oth

er

offic

es, in

cludi

ng C

omm

unity

Affa

irs a

nd O

SA, t

o hi

ghlig

ht in

tera

ctio

ns w

ith th

e pu

blic

and

stak

ehol

der g

roup

s on

the

CFPB

blo

g.

• CE

E is

begi

nnin

g a

pilo

t pro

gram

to p

rodu

ce 2

to 3

blo

g po

sts

a we

ek a

roun

d a

“CFP

B in

you

r com

mun

ity th

eme,

” whi

ch w

ill fe

atur

e re

ad-o

uts

and

copi

es o

f pr

epar

ed re

mar

ks o

f sen

ior C

FPB

offic

ials

mee

ting

with

ext

erna

l sta

keho

lder

s (i.

e., c

omm

unity

and

indu

stry

gro

ups)

aro

und

the

coun

try.

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce e

lem

ent

Cons

isten

t pro

mot

ion

of o

ur m

oney

edu

catio

n co

nten

t suc

h as

tip o

f the

day

to o

ther

sit

es/c

hann

els

• W

hile

Con

sum

er E

ngag

emen

t is w

orkin

g in

col

labo

ratio

n wi

th th

e O

ffice

of

Fina

ncia

l Edu

catio

n to

pla

n fo

r pos

ting,

pro

mot

ing

and

dist

ribut

ing

this

cont

ent

as s

oon

as it

is av

aila

ble

for p

ublic

atio

n, s

ome

of th

is wo

rk w

ill be

dep

ende

nt

on th

e de

velo

pmen

t of t

he b

luep

rint m

entio

ned

abov

e.

• W

e re

com

men

d Co

nsum

er E

ngag

emen

t co

ntin

ue to

pla

n fo

r the

pro

mot

ion

of e

duca

tion

cont

ent t

o en

sure

pro

mot

ion

is as

sea

mle

ss a

s po

ssib

le o

nce

it is

read

y fo

r pub

licat

ion.

Web

por

tals

for t

he e

mpo

werm

ent o

ffices

plu

s O

FE

(My

Fi) a

nd F

air L

endi

ng

• Th

e of

fice

of F

air L

endi

ng a

nd E

qual

Opp

ortu

nity

’s we

b po

rtal a

nd a

n im

prov

ed

site

for t

he O

ffice

of C

omm

unity

Ban

ks a

nd C

redi

t Uni

ons

is se

t to

laun

ch th

e we

ek o

f Oct

ober

2nd

. •

The

web

porta

l for O

SA is

sch

edul

ed to

laun

ch la

ter i

n O

ctob

er.

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce e

lem

ent

One

to tw

o in

itial o

fferin

gs to

eng

age

the

publ

ic on

m

oney

issu

es o

r mon

ey d

ecisi

on-m

akin

g in

clo

se

coop

erat

ion

with

OFE

•

This

work

is d

epen

dent

on

the

cons

umer

exp

erie

nce

blue

prin

t des

crib

ed

abov

e.

• W

e re

com

men

d CF

PB m

ove

forw

ard

with

pla

ns

for t

he c

onsu

mer

exp

erie

nce

blue

prin

t for

de

liver

y in

Dec

embe

r 201

1.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

86

Org

aniz

atio

nal G

oal

Dem

onst

rate

d Pe

rform

ance

Fi

ndin

g / R

ecom

men

datio

n

Desig

n an

d im

plem

enta

tion

of c

alen

dar f

or u

se o

f di

rect

em

ail to

ol

• Du

e to

the

CFPB

-wid

e st

rate

gy p

roce

ss in

pla

ce, it

was

det

erm

ined

that

an

inte

rim d

irect

mai

l stra

tegy

wou

ld b

e im

plem

ente

d un

til co

mpl

etio

n of

the

CFPB

-wid

e pr

oces

s wa

s co

mpl

ete.

•

Cons

umer

Eng

agem

ent le

d a

cros

s-di

visio

nal e

ffort

to d

evel

op th

e in

terim

ed

itoria

l cal

enda

r and

stra

tegy

for b

uild

ing

list s

egm

ents

(e.g

., a

targ

eted

list o

f sm

all fi

nanc

ial s

ervic

es p

rovid

ers)

that

was

put

in p

lace

in S

epte

mbe

r. •

Cons

umer

Eng

agem

ent w

ill be

hea

vily

invo

lved

in d

evel

opm

ent o

f a lo

nger

-te

rm s

trate

gy th

at w

ill fo

llow

the

final

CFP

B-wi

de o

rgan

izatio

nal s

trate

gy.

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce e

lem

ent

Web

stre

amin

g ca

pacit

y (fo

r Oct

OSA

con

veni

ng,

enfo

rcem

ent h

earin

gs)

• Co

nsum

er E

ngag

emen

t coo

rdin

ated

with

CFP

B te

chno

logy

and

info

rmat

ion

offic

es to

suc

cess

fully

stre

am R

aj D

ate’

s Ph

ilade

lphi

a sp

eech

on

9/15

/201

1.

• Th

ere

are

plan

s to

live

stre

am tw

o m

ore

CFPB

eve

nts

this

mon

th.

• W

e en

cour

age

CFPB

to c

ontin

ue to

use

live

stre

amin

g as

a c

omm

unica

tions

tool

, as

it allo

ws

thos

e wh

o ar

e un

able

to a

ttend

CFP

B ev

ents

th

e op

portu

nity

to b

e a

part

of th

em.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

87

Tab

le 2

1: A

chie

vem

ent

of O

rgan

izat

ion

al G

oals

(S

ervi

cem

emb

er A

ffai

rs)

Org

aniz

atio

nal G

oal

Dem

onst

rate

d Pe

rform

ance

Fi

ndin

g / R

ecom

men

datio

n

Deve

lop

milit

ary

cont

ent f

or w

ebsit

e/so

cial m

edia

• O

SA h

as d

evel

oped

num

erou

s so

urce

s of

web

con

tent

, inclu

ding

a

spec

ific la

ndin

g pa

ge o

n th

e CF

PB w

ebsit

e fo

r ser

vicem

embe

rs th

at

high

light

s wh

o O

SA is

and

wha

t the

y ar

e do

ing

for m

embe

rs o

f the

m

ilitar

y an

d th

eir f

amilie

s, a

nd n

umer

ous

blog

pos

ts a

nd a

rticle

s re

gard

ing

the

happ

enin

gs in

side

OSA

and

the

even

ts, s

peec

hes,

et

c. th

at H

olly

Petra

eus

has

parti

cipat

ed in

.

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce

elem

ent

Host

con

veni

ng in

Oct

ober

con

cern

ing

best

pr

actic

es in

offe

ring

finan

cial p

rodu

cts

to m

ilitar

y

• A

Requ

est f

or In

form

atio

n wa

s re

leas

ed in

the

Fede

ral R

egist

er o

n Se

ptem

ber 6

, 201

1 fo

r inf

orm

atio

n on

the

prod

ucts

and

ser

vices

that

ar

e un

ique

to s

ervic

emem

bers

and

thei

r fam

ilies.

The

Req

uest

for

Info

rmat

ion

was

diss

emin

ated

thro

ugh

all m

edia

and

dist

ribut

ion

chan

nels.

•

The

orig

inal

Oct

ober

con

veni

ng d

ate

was

mov

ed to

Nov

embe

r 8,

2011

in a

n ef

fort

to a

void

logi

stica

l con

flicts

with

Stu

dent

and

Old

er

Amer

ican

rollo

ut e

vent

s.

• O

SA is

in fu

ll pla

nnin

g m

ode

for t

he c

onve

ning

, put

ting

toge

ther

pa

nels,

que

stio

n se

ts a

nd fig

urin

g ou

t logi

stics

. Ho

weve

r, be

caus

e of

a c

onflic

t with

Pre

siden

t Oba

ma’

s Fi

nanc

ial E

duca

tion

Sum

mit,

OSA

’s co

nven

ing

may

be

mov

ed a

gain

.

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce

elem

ent

Eval

uate

finan

cial e

duca

tion

at m

ilitar

y ba

sic

train

ing

• M

embe

rs o

f OSA

hav

e vis

ited

basic

trai

ning

site

s of

two

milit

ary

divis

ions

: the

Nav

y an

d M

arin

e Co

rps.

•

OSA

is s

ched

uled

to v

isit t

he b

asic

train

ing

site

for t

he A

rmy

at F

ort

Jack

son

on N

ovem

ber 4

, 201

1.

• Vi

sits

to th

e Ai

r For

ce a

nd C

oast

Gua

rd b

asic

train

ing

sites

are

cu

rrent

ly be

ing

sche

dule

d.

• So

far,

OSA

has

mad

e on

ly in

itial o

bser

vatio

ns, b

ut w

ants

to fo

cus

on th

e be

ginn

ing

of m

ilitar

y ca

reer

s an

d th

e us

e of

tech

nolo

gy to

m

oder

nize

finan

cial e

duca

tion

for n

ew m

embe

rs o

f the

milit

ary.

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce

elem

ent

Deve

lop

revis

ed c

urric

ulum

for n

ew re

crui

ts in

co

ordi

natio

n wi

th th

e De

partm

ent o

f Def

ense

(D

oD)

• Th

e de

velo

pmen

t of r

evise

d cu

rricu

lum

for n

ew re

crui

ts is

und

erwa

y wi

th D

oD; O

SA is

in a

dat

a-ga

ther

ing

phas

e.

• In

itial o

bser

vatio

ns s

how

a va

rianc

e am

ong

curri

culu

ms

acro

ss

milit

ary

divis

ions

.

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce

elem

ent

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

88

Org

aniz

atio

nal G

oal

Dem

onst

rate

d Pe

rform

ance

Fi

ndin

g / R

ecom

men

datio

n

Prov

ide

milit

ary

expe

rtise

for C

onsu

mer

Re

spon

se: s

crip

ts, F

AQs,

refe

rrals,

tailo

red

assis

tanc

e

• Al

l Con

sum

er R

espo

nse

scrip

ts, F

AQs,

refe

rrals,

and

tailo

red

assis

tanc

e wi

th re

spec

t to

serv

icem

embe

rs h

ave

been

dev

elop

ed

with

ext

ensiv

e O

SA in

put.

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce

elem

ent

Raise

awa

rene

ss o

f CFP

B/O

SA th

roug

h m

edia

, sp

eech

es a

nd o

utre

ach

to b

usin

ess

and

gove

rnm

ent

• CF

PB a

nd O

SA h

ave

both

ext

ensiv

ely

used

CFP

B’s

blog

to

diss

emin

ate

info

rmat

ion

rega

rdin

g th

e go

ings

on

in th

e bu

reau

as

a wh

ole

and

OSA

. Bo

th h

ave

used

the

blog

to in

form

the

publ

ic on

sp

eech

es a

nd e

vent

s th

at h

ave

take

n pl

ace,

as

well a

s as

ked

for

the

publ

ic’s

inpu

t on

mul

tiple

issu

es.

• Ho

lly P

etra

eus

has

give

n 22

spe

eche

s sin

ce h

er a

ppoi

ntm

ent a

s Di

rect

or o

f OSA

in J

anua

ry 2

011.

Exa

mpl

es o

f gro

ups

she

has

spok

en to

inclu

de w

ound

ed s

oldi

ers

at W

alte

r Ree

d Na

tiona

l Milit

ary

Med

ical C

ente

r, th

e As

socia

tion

of M

ilitar

y Ba

nks,

the

Arm

y JA

G

Scho

ol, t

he W

ound

ed W

arrio

rs p

roje

ct, a

nd m

embe

rs o

f the

U.S

. Ho

use

and

Sena

te.

• M

embe

rs o

f the

OSA

team

hav

e he

ld n

umer

ous

town

halls

and

ro

undt

able

s an

d tra

vele

d to

milit

ary

base

s ac

ross

the

coun

try to

cr

eate

a fe

edba

ck lo

op th

roug

h wh

ich O

SA c

an e

duca

te m

embe

rs

of th

e m

ilitar

y on

wha

t is g

oing

on

insid

e th

e of

fice

and

OSA

can

le

arn

from

milit

ary

mem

bers

wha

t issu

es a

re th

e m

ost im

porta

nt to

th

em.

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce

elem

ent

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

89

Tab

le 2

2: A

lign

men

t w

ith

Per

form

ance

Sta

nd

ard

s (G

oals

an

d O

bje

ctiv

es)

Goa

l Sc

ore

Sum

mar

y of

Per

form

ance

Pr

iorit

y F

indi

ng /

Reco

mm

enda

tion

Build

fam

iliarit

y wi

th th

e CF

PB

bran

d

Build

ing

bran

d aw

aren

ess

take

s tim

e. T

he C

FPB

has

esta

blish

ed a

sol

id fo

unda

tion

for a

chie

ving

fam

iliarit

y am

ong

“eve

ryda

y Am

erica

ns” a

nd h

as h

ad a

stro

ng in

tere

st fr

om

cons

umer

s gi

ven

its s

hort

life s

pan.

How

ever

, its

work

in th

is ar

ea is

onl

y be

ginn

ing

to a

chie

ve its

goa

ls an

d m

inor

in

cons

isten

cies

in th

e us

e of

bra

nd-re

late

d la

ngua

ge c

ould

slo

w aw

aren

ess.

Low

• W

e re

com

men

d th

e CF

PB re

visit t

he th

ree

area

s it h

as

publ

icly

com

mun

icate

d in

prin

t its

man

date

, miss

ion,

visi

on

and

valu

es a

nd m

ake

effo

rts to

redu

ce th

e va

rianc

es a

nd

rem

ain

as c

onsis

tent

as

poss

ible

acr

oss

all m

ediu

ms.

•

Spec

ifical

ly, d

iscon

tinue

usin

g th

e “M

issio

n” la

ngua

ge a

s it’s

du

plica

tive

of th

e St

atut

ory

Purp

ose

and

Obj

ectiv

es (b

oth

of

which

use

lang

uage

that

is c

lear

and

sui

tabl

e fo

r con

sum

er

facin

g co

mm

unica

tion)

, kee

p th

e vis

ion

and

use

it as

a pa

rt of

the

lang

uage

on

the

webs

ite a

nd in

con

sum

er fa

cing

vehi

cles

as p

art o

f a s

ectio

n de

vote

d to

“wha

t doe

s th

is m

ean

for y

ou”.

Enga

ge th

e pu

blic

The

CFPB

is e

mph

asizi

ng th

is ar

ea a

nd u

nder

stan

dabl

y so

gi

ven

that

suc

cess

ful e

ngag

emen

t of t

he p

ublic

can

hel

p it

achi

eve

othe

r goa

ls in

cludi

ng b

rand

fam

iliarit

y an

d illu

stra

tion

of c

onsu

mer

impa

ct.

CFPB

has

mad

e a

cons

cious

effo

rt to

en

gage

with

the

publ

ic th

roug

h its

web

site

and

blog

, as

well a

s us

ing

thos

e pl

atfo

rms

for s

olici

ting

publ

ic fe

edba

ck o

n CF

PB

initia

tives

(e.g

., Re

ques

t for

Com

men

t issu

ed fo

r “la

rger

pa

rticip

ant”

defin

ition,

and

Kno

w Be

fore

You

Owe

feed

back

).

High

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Expl

ain

polic

y de

liver

able

s in

pl

ain

Engl

ish

The

webs

ite is

the

prim

ary

exte

rnal

com

mun

icatio

ns to

ol fo

r th

e CF

PB to

reac

h th

e co

nsum

er a

nd it

has

set t

he to

ne fo

r co

mm

unica

ting

in “p

lain

Eng

lish”

. CF

PB h

as m

ade

a co

ncer

ted

effo

rt to

tran

slate

com

plex

finan

cial la

ngua

ge in

to

lang

uage

that

any

one

coul

d un

ders

tand

, inclu

ding

dev

elop

ing

and

mai

ntai

ning

the

cont

ent o

f the

CFP

B’s

webs

ite a

t an

8th

grad

e re

adin

g le

vel.

Med

ium

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

90

Goa

l Sc

ore

Sum

mar

y of

Per

form

ance

Pr

iorit

y F

indi

ng /

Reco

mm

enda

tion

Illust

rate

the

cons

umer

impa

ct

Brin

ging

the

stor

ies

of h

ow th

e co

nsum

er is

impa

cted

is th

e m

issio

n of

the

depa

rtmen

t of C

onsu

mer

Eng

agem

ent a

nd

Educ

atio

n. T

he C

FPB

has

also

aim

ed to

use

“hum

an fa

ces”

of

the

bure

au to

com

mun

icate

impa

ct to

con

sum

ers.

For

ex

ampl

e, th

e CF

PB a

ppoi

nted

Hol

ly Pe

traeu

s as

the

Dire

ctor

of

the

Offic

e of

Ser

vicem

embe

r Affa

irs, w

ho a

s th

e wi

fe a

nd

mot

her o

f ser

vicem

embe

rs h

as a

uni

que

know

ledg

e an

d un

ders

tand

ing

of th

e liv

es o

f ser

vicem

embe

rs.

Mrs

. Pet

raeu

s’ Ne

w Yo

rk Tim

es o

p-ed

in S

epte

mbe

r 201

1 on

how

for-p

rofit

scho

ols

are

takin

g ad

vant

age

of s

ervic

emem

bers

and

thei

r fa

milie

s fu

rther

dem

onst

rate

s he

r uni

que

and

appr

opria

te

know

ledg

e ba

se.

CFPB

has

also

use

d a

Tel

l You

r Sto

ry

stra

tegy

to d

emon

stra

te re

al c

onsu

mer

sto

ries

to th

e pu

blic.

High

•

We

reco

mm

end

the

CFPB

con

tinue

to fin

d wa

ys to

hig

hlig

ht

othe

r fac

es w

ithin

the

bure

au a

s it g

rows

and

mat

ures

.

Max

imize

bur

eau

reso

urce

s

The

CFPB

’s de

term

inat

ion

to n

ot le

t lim

ited

staf

f be

an e

xcus

e is

appr

ecia

ble.

It h

as m

ade

the

mos

t of t

he re

sour

ces

it has

an

d ha

s m

ade

a co

nscio

us e

ffort

to e

ngag

e di

ffere

nt m

embe

rs

of d

iffere

nt te

ams

acro

ss th

e or

gani

zatio

n to

max

imize

resu

lts.

(e.g

., th

e ov

erla

ppin

g of

the

Cons

umer

Eng

agem

ent,

Com

mun

ity A

ffairs

and

Med

ia R

elat

ions

team

s).

Med

ium

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Touc

h m

ost s

igni

fican

t na

tiona

l and

regi

onal

co

nsum

er, c

ivil r

ight

s, a

nd

gras

sroo

ts a

dvoc

acy

orga

niza

tions

in th

e fin

ancia

l se

rvice

s sp

ace

(~20

0).

Ove

r the

pas

t yea

r, CF

PB h

as h

eld

near

ly 25

0 m

eetin

gs w

ith

grou

ps in

cludi

ng A

ARP,

AFR

, You

th, N

CLR,

Lat

ino

grou

ps,

NAAC

P, c

onsu

mer

gro

ups,

civi

l rig

hts

grou

ps, f

aith

gro

ups,

et

c.

High

• G

iven

how

signi

fican

t the

effo

rts h

ave

been

to e

ngag

e co

mm

unity

gro

ups,

a tr

acke

r to

orga

nize

the

CFPB

’s ef

forts

in

this

area

will

help

it te

ll its

sto

ry o

f who

it’s

reac

hing

and

ho

w it’s

reac

hing

them

. The

trac

ker c

ould

inclu

de a

list o

f gr

oups

the

CFPB

has

eng

aged

, the

last

poi

nt o

f con

tact

, na

ture

of t

he c

onta

ct, n

ext s

teps

to fu

rther

eng

agin

g th

e or

gani

zatio

n an

d pe

rhap

s so

me

asse

ssm

ent o

f the

deg

ree

to w

hich

that

org

aniza

tion

is cu

rrent

ly en

gage

d.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

91

Goa

l Sc

ore

Sum

mar

y of

Per

form

ance

Pr

iorit

y F

indi

ng /

Reco

mm

enda

tion

Deve

lop

“ear

ly wa

rnin

g”

info

rmat

ion

from

the

field

and

m

ake

avai

labl

e to

all C

FPB

repo

rts a

nd s

tudi

es fr

om

cons

umer

, civi

l rig

hts,

and

co

mm

unity

gro

ups

abou

t im

pact

s of

spe

cific

finan

cial

serv

ice p

rodu

cts

and

prac

tices

on

neig

hbor

hood

s an

d co

mm

unitie

s.

The

mee

tings

men

tione

d ab

ove

as w

ell a

s th

e ro

undt

able

di

scus

sion

s th

e C

FPB

hold

s—of

ten

in c

onju

nctio

n w

ith a

la

rger

CFP

B-ho

sted

eve

nt in

a c

ity (e

.g.,

Phila

delp

hia

on

9/15

/11)

—se

rve

as p

roac

tive

solic

itatio

ns fo

r fee

dbac

k fro

m th

e “fi

eld”

. In

addi

tion,

the

rela

tions

hips

dev

elop

ed

with

the

grou

ps o

utlin

ed a

bove

cre

ate

a fe

edba

ck lo

op s

o th

at th

ose

grou

ps h

ave

acce

ss to

the

CFP

B to

sha

re

info

rmat

ion.

Low

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce e

lem

ent

Crea

te s

earc

habl

e co

nten

t re

sour

ce o

f tho

se re

ports

and

st

udie

s, a

nd p

rovid

e pe

riodi

c up

date

s fo

r all C

FPB

staf

f of

the

inpu

t rec

eive

d fro

m th

ese

grou

ps.

Whi

le th

e C

FPB

is in

the

proc

ess

of d

evel

opin

g th

e se

arch

able

con

tent

reso

urce

, as

soon

as

Con

sum

er

Affa

irs re

ceiv

es b

oth

inte

rnal

and

ext

erna

l rep

orts

, the

y sh

are

exce

rpts

and

key

poi

nts

with

oth

er C

FPB

staf

f.

Low

• Th

e co

mpl

ete

deve

lopm

ent o

f a s

earc

habl

e co

nten

t re

sour

ce w

ill be

a te

rrific

way

to s

hare

info

rmat

ion

and

max

imize

bur

eau

reso

urce

s.

Be a

reso

urce

to c

onsu

mer

, civ

il rig

hts

and

nonp

rofit

orga

niza

tions

, and

hel

p al

l pa

rts o

f the

CFP

B ac

cess

kn

owle

dge

and

info

rmat

ion

from

thos

e gr

oups

.

Roun

dtab

les

held

by

the

CFPB

brin

g to

geth

er k

ey

cons

tituen

cy g

roup

s, in

cludi

ng o

lder

Am

erica

ns, s

tude

nts,

and

m

inor

ity g

roup

s an

d cr

eate

a tw

o-wa

y di

alog

ue. A

n in

tern

al

week

ly lo

ok-a

-hea

d do

cum

ent is

pro

vided

to a

ll CFP

B pe

rson

nel s

o th

ey c

an s

ee u

pcom

ing

exte

rnal

mee

tings

takin

g pl

ace

in th

e ev

ent it

mak

es s

ense

for o

ther

gro

ups

with

in

CFPB

to p

artic

ipat

e as

wel

l. Add

itiona

l res

ourc

es in

clude

: so

cial m

edia

, the

web

site

and

the

800

num

ber.

Med

ium

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Adhe

re to

Sec

tion

1013

(a)(5

) of

the

Dodd

-Fra

nk A

ct

CFPB

has

eva

luat

ed th

e O

mbu

dsm

an fu

nctio

n wi

thin

oth

er

fede

ral a

genc

ies

and

cond

ucte

d so

me

inte

rnal

pla

nnin

g.

Addi

tiona

lly, a

det

aile

e ha

s be

en a

ssig

ned

to th

e O

ffice

of th

e O

mbu

dsm

an.

Howe

ver,

the

Om

buds

man

func

tion

is no

t yet

up

and

runn

ing

as a

com

plet

e fu

nctio

ning

offic

e.

High

• Th

e po

sitio

n of

Om

buds

man

is m

anda

ted

by th

e Do

dd-

Fran

k Ac

t in E

xter

nal A

ffairs

and

its ro

le w

ithin

the

orga

niza

tion

is an

impo

rtant

one

. Fur

ther

, a d

etai

lee

in th

is po

sitio

n co

uld

face

som

e ch

alle

nges

in fu

lfillin

g a

role

that

re

quire

s in

tern

al in

vest

igat

ion

give

n th

at e

mpl

oyee

s co

uld

view

him

/her

as

tem

pora

ry a

nd b

e le

ss th

an fu

lly

coop

erat

ive.

• Th

us w

e re

com

men

d th

at th

e CF

PB fil

l the

posit

ion

with

a

full-t

ime

empl

oyee

as

soon

as

poss

ible

.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

92

Goa

l Sc

ore

Sum

mar

y of

Per

form

ance

Pr

iorit

y F

indi

ng /

Reco

mm

enda

tion

Adhe

re to

Sec

tion

1014

of t

he

Dodd

-Fra

nk A

ct

W

ithou

t a D

irect

or, C

FPB

is st

atut

orily

una

ble

to h

ave

a fu

nctio

ning

Con

sum

er A

dviso

ry B

oard

. Hi

gh

• W

hile

the

Cons

umer

Adv

isory

Boa

rd h

as a

n im

porta

nt

func

tion

with

in th

e or

gani

zatio

n an

d is

man

date

d by

the

Dodd

-Fra

nk A

ct in

ext

erna

l affa

irs, b

y la

w, th

e Bo

ard

cann

ot

be c

reat

ed u

ntil t

he D

irect

or o

f the

CFP

B is

in p

lace

.

• Th

us w

e re

com

men

d th

e Bo

ard

be c

reat

ed a

s so

on a

s po

ssib

le fo

llowi

ng th

e ap

prov

al o

f a D

irect

or.

Adhe

re to

Title

10,

Sec

tion

1013

(e) o

f the

Dod

d-Fr

ank

Act

CFPB

has

cre

ated

the

Offic

e of

Ser

vicem

embe

r Affa

irs.

High

•

In o

ur ju

dgm

ent,

base

d on

the

info

rmat

ion

prov

ided

, the

CF

PB h

as m

et its

obl

igat

ions

in th

is ar

ea.

Adhe

re to

Title

10,

Sec

tion

1013

(g) o

f the

Dod

d-Fr

ank

Act

As o

utlin

ed in

Dod

d-Fr

ank,

CFP

B is

not r

equi

red

to h

ave

crea

ted

the

Offic

e of

Fin

ancia

l Pro

tect

ion

for O

lder

Am

erica

ns

until

Janu

ary

21, 2

012.

Alth

ough

the

Offic

e of

Fin

ancia

l Pr

otec

tion

for O

lder

Am

erica

ns is

not

eva

luat

ed in

this

repo

rt,

since

the

Offic

e wa

s cr

eate

d on

Aug

ust 2

8, th

e ac

ting

dire

ctor

of

the

Offic

e m

et w

ith n

umer

ous

gove

rnm

enta

l offic

es a

nd

stak

ehol

ders

invo

lved

in is

sues

affe

ctin

g O

lder

Am

erica

ns,

cons

isten

t with

CFP

B’s

stat

utor

y m

anda

te. T

he p

erm

anen

t As

sista

nt D

irect

or w

ill be

on

boar

d on

Oct

ober

17.

Med

ium

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Adhe

re to

Title

10,

Sec

tion

1035

of t

he D

odd-

Fran

k Ac

t

As o

utlin

ed in

the

Dodd

-Fra

nk A

ct, C

FPB

is no

t req

uire

d to

ha

ve d

esig

nate

d a

Priva

te E

duca

tion

Loan

Om

buds

man

unt

il O

ctob

er 2

1, 2

011.

Give

n th

at, t

he fu

nctio

n of

Priv

ate

Educ

atio

n Lo

an O

mbu

dsm

an is

not

eva

luat

ed in

the

rem

aind

er

of th

is re

port.

High

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Adhe

re to

Title

10,

Sec

tion

1013

(d) o

f the

Dod

d-Fr

ank

Act

CFPB

has

cre

ated

the

Offic

e of

Fin

ancia

l Edu

catio

n. H

owev

er,

give

n th

e ne

wnes

s of

the

offic

e at

this

time,

it is

not e

valu

ated

in

the

rem

aind

er o

f thi

s re

port.

Hi

gh

• W

e re

com

men

d th

at th

e CF

PB c

ontin

ue w

orkin

g to

ward

this

bein

g a

fully

func

tiona

l offic

e.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

93

Goa

l Sc

ore

Sum

mar

y of

Per

form

ance

Pr

iorit

y F

indi

ng /

Reco

mm

enda

tion

Adhe

re to

the

Free

dom

of

Info

rmat

ion

Act (

FOIA

)

CFPB

has

dem

onst

rate

d ex

empl

ary

com

plia

nce

with

FO

IA.

The

FOIA

Offic

e ha

s ad

opte

d a

“disc

retio

nary

” app

roac

h un

der

which

tran

spar

ency

take

s pr

eced

ence

. At

this

stag

e in

its

yout

hful

hist

ory,

the

FOIA

Offic

e ha

s cr

eate

d an

d be

gun

impl

emen

ting

inte

rnal

pro

cess

and

pro

cedu

res

for r

espo

ndin

g to

FO

IA re

ques

ts in

a s

tream

lined

man

ner,

and

has

mad

e sig

nific

ant e

fforts

to e

nsur

e th

at a

ll app

ropr

iate

offic

es w

ithin

CF

PB a

re m

ade

awar

e of

spe

cific

FOIA

requ

ests

that

may

be

of in

tere

st to

them

. No

tabl

y, C

FPB’

s ap

proa

ch c

ould

bec

ome

the

new

benc

hmar

k fo

r FO

IA c

ompl

ianc

e.

High

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Adhe

re to

the

E-G

over

nmen

t Ac

t of 2

002

CF

PB h

as d

evel

oped

and

impl

emen

ted

an IT

stru

ctur

e th

at

adhe

res

to th

e E-

Gov

ernm

ent A

ct, in

cludi

ng F

ISM

A.

High

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Adhe

re to

the

Fede

ral

Fund

ing

and

Acco

unta

bility

Tr

ansp

aren

cy A

ct (F

FATA

)

CFPB

pos

ts a

ward

ed fe

dera

l con

tract

s to

the

CFPB

web

site.

Hi

gh

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce e

lem

ent

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

94

Goa

l Sc

ore

Sum

mar

y of

Per

form

ance

Pr

iorit

y F

indi

ng /

Reco

mm

enda

tion

Tran

spar

ency

with

the

publ

ic

CFPB

sta

keho

lder

s cle

arly

expr

esse

d th

at a

key

obj

ectiv

e fo

r th

e bu

reau

as

a wh

ole,

and

for t

heir

indi

vidua

l dep

artm

ents

, is

to b

e tra

nspa

rent

to th

e pu

blic

thro

ugh

a va

riety

of d

iffere

nt

med

ium

s. T

his

is so

met

hing

that

was

“bak

ed in

to” t

he C

FPB

at in

cept

ion

and

has

been

mai

ntai

ned

since

. Th

e bu

reau

has

de

mon

stra

ted

its c

omm

itmen

t to

trans

pare

ncy

by b

egin

ning

to

post

Eliz

abet

h W

arre

n’s

cale

ndar

onl

ine

on N

ovem

ber 2

4,

2010

, eve

n be

fore

laun

chin

g th

e CF

PB w

ebsit

e. A

dditio

nally

, th

e CF

PB h

as h

ad n

early

100

one

-on-

one

conv

ersa

tions

with

M

embe

rs o

f Con

gres

s fro

m b

oth

sides

of t

he a

isle,

it ha

s m

et

with

a n

umbe

r of o

pen

gove

rnm

ent o

rgan

izatio

ns, a

nd h

as

prov

ided

upd

ates

on

hirin

g, in

cludi

ng lis

ting

the

nam

es a

nd

expe

rienc

e of

all s

enio

r lea

ders

hip,

and

pos

ting

upda

tes

to

prov

ide

a sn

apsh

ot o

f how

the

CFPB

is s

pend

ing

fund

s. F

utur

e co

nsid

erat

ions

in th

is ar

ea in

clude

mak

ing

addi

tiona

l do

cum

ents

and

sen

ior l

eade

rshi

p ca

lend

ars

avai

labl

e on

line,

an

d an

eFO

IA s

yste

m.

The

bure

au is

also

eva

luat

ing

the

poss

ibilit

y of

pos

ting

cons

umer

com

plai

nts

onlin

e wh

en th

ey

are

rece

ived.

High

•

Iden

tify w

ays

to s

hare

with

oth

er a

genc

ies

and

mak

e pu

blic

how

the

CFPB

has

gon

e ab

out it

s FO

IA p

roce

ss. T

his

is an

ar

ea C

FPB

can

exhi

bit s

ome

thou

ght le

ader

ship

.

Educ

ate

the

publ

ic on

who

CF

PB is

and

wha

t the

y ar

e do

ing

Mul

tiple

CFP

B st

akeh

olde

rs e

xpre

ssed

that

the

key

goal

for

them

as

exte

rnal

com

mun

icato

rs is

to e

nsur

e th

at c

onsu

mer

s kn

ow w

ho C

FPB

is an

d wh

at th

e bu

reau

is d

oing

. Th

us fa

r, CF

PB h

as s

ucce

ssfu

lly u

sed

its w

ebsit

e an

d bl

og to

co

mm

unica

te w

hat is

goi

ng o

n in

side

the

bure

au a

s we

ll as

to

dem

onst

rate

its c

omm

itmen

t to

trans

pare

ncy

as d

escr

ibed

pr

evio

usly.

Add

itiona

lly, C

FPB

cons

isten

tly u

ses

back

chan

nel

com

mun

icatio

ns (i

.e.,

pers

onal

pho

ne c

alls

to c

onsu

mer

gr

oups

) to

cont

inue

to e

duca

te th

e pu

blic

on C

FPB

oper

atio

ns

(e.g

., th

roug

h th

e Co

mm

unity

Affa

irs O

ffice,

all j

ob

anno

unce

men

ts a

re s

ent t

o th

e O

ffice’

s lis

t of c

onsu

mer

gr

oups

).

Med

ium

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

95

Goa

l Sc

ore

Sum

mar

y of

Per

form

ance

Pr

iorit

y F

indi

ng /

Reco

mm

enda

tion

Mee

t with

com

mun

ity b

anke

rs

from

all 5

0 st

ates

CFPB

not

onl

y m

et b

ut e

xcee

ded

thei

r goa

l of m

eetin

g wi

th

com

mun

ity b

anke

rs fr

om a

ll 50

stat

es w

ithin

one

yea

r; in

fact

, th

ey re

ache

d th

eir g

oal w

ell b

efor

e th

e de

adlin

e.

The

CFPB

al

so c

ontin

ues

outre

ach

to c

omm

unity

ban

kers

(e.g

., du

ring

the

week

s of

Sep

tem

ber 1

2th a

nd 1

9th, C

FPB

spok

e wi

th

com

mun

ity b

anke

rs fr

om 1

7 di

ffere

nt s

tate

s).

Med

ium

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

CFPB

-wid

e sh

ared

visi

on o

f th

e ro

le o

f eng

agem

ent a

nd

the

desir

ed im

pact

on

the

publ

ic of

our

eng

agem

ent

work

Cons

umer

Eng

agem

ent h

as h

eld

two

work

ing

sess

ions

to

defin

e th

e of

fice’

s m

issio

n an

d vis

ion,

and

a d

raft

miss

ion

stat

emen

t has

bee

n de

velo

ped.

The

Offic

e ha

s al

so w

orke

d in

co

llabo

ratio

n wi

th o

ther

CFP

B of

fices

to d

evel

op lo

ng-te

rm

visio

ns fo

r cur

rent

CFP

B di

gita

l eng

agem

ent o

fferin

gs.

High

• Co

nsum

er E

ngag

emen

t sho

uld

cont

inue

to w

ork

on d

efin

ing

its o

wn m

issio

n an

d vis

ion,

ens

urin

g th

at th

ey a

re in

ag

reem

ent w

ith th

e m

issio

n an

d vis

ion

of th

e CF

PB a

s a

whol

e. D

evel

opin

g a

coor

dina

ted

miss

ion

and

visio

n wi

ll st

reng

then

the

CFPB

bra

nd o

ver t

ime.

Org

aniza

tiona

l stru

ctur

e,

posit

ion

desc

riptio

ns, c

aree

r la

dder

s, re

crui

tmen

t pla

n, a

nd

polic

ies

to s

uppo

rt th

e wo

rk

(exa

mpl

e, “b

log

on o

ther

sit

es” p

olicy

)

Whi

le C

onsu

mer

Eng

agem

ent h

as d

efer

red

recr

uitin

g ef

forts

to

2Q 2

012,

it ha

s fo

cuse

d its

atte

ntio

n to

cur

rent

ly gr

owin

g th

e of

fice

from

two

to fo

ur p

erso

nnel

. Po

sitio

n de

scrip

tions

and

ca

reer

ladd

ers

for t

hose

des

crip

tions

are

eith

er in

dev

elop

men

t or

hav

e be

en d

evel

oped

. Ad

ditio

nally

, Con

sum

er

Enga

gem

ent h

as re

cogn

ized

and

iden

tified

pol

icies

for

deve

lopm

ent,

disc

ussio

n an

d im

plem

enta

tion

that

are

in th

e de

velo

pmen

t pro

cess

cur

rent

ly.

High

•

Cons

umer

Eng

agem

ent s

houl

d m

ove

quick

ly to

fill th

e of

fice

and

deve

lop

the

appr

opria

te p

lans

and

pol

icies

to a

llow

it to

effe

ctive

ly op

erat

e.

Blue

prin

t for

the

CFPB

“c

onsu

mer

exp

erie

nce,

” co

ncep

ts fo

r CFP

B pr

oduc

t an

d se

rvice

offe

rings

suc

h as

in

tera

ctive

tool

s, p

lus

plan

wi

th tim

elin

e to

brin

g on

e or

m

ore

of th

ose

mor

e sig

nific

ant

tool

s to

frui

tion

A bl

uepr

int f

or th

e CF

PB c

onsu

mer

exp

erie

nce

is on

trac

k an

d on

bud

get f

or d

elive

ry in

Dec

embe

r 201

1. T

he w

ork

is be

ing

done

thro

ugh

an o

utsid

e co

ntra

ctor

, who

will

pres

ent a

dra

ft bl

uepr

int t

o CF

PB le

ader

ship

the

week

of O

ctob

er 1

0th.

Med

ium

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

IT s

olut

ion

for e

dito

rial

work

flow

and

cont

ent

man

agem

ent s

yste

m fo

r Co

nsum

erFi

nanc

e.go

v

Cons

umer

Eng

agem

ent h

as re

ques

ted

the

appr

opria

te b

udge

t an

d pe

rson

nel r

esou

rces

for t

his

proj

ect,

and

disc

ussio

ns o

n th

e pr

ojec

t’s s

cope

, tim

elin

e an

d re

quire

men

ts h

ave

begu

n.

Med

ium

•

We

reco

mm

end

Cons

umer

Eng

agem

ent c

ontin

ue to

wor

k wi

th th

e te

chno

logy

and

info

rmat

ion

offic

es w

ithin

CFP

B to

de

velo

p th

e sc

ore,

requ

irem

ents

and

timel

ine

of th

e pr

ojec

t.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

96

Goa

l Sc

ore

Sum

mar

y of

Per

form

ance

Pr

iorit

y F

indi

ng /

Reco

mm

enda

tion

Impr

oved

bus

ines

s pr

oces

s fo

r gen

erat

ing

and

clear

ing

cont

ent f

or u

se o

n ou

r web

site

and

othe

r ele

ctro

nic

chan

nels

Beca

use

the

CFPB

ove

rall o

rgan

izatio

nal s

trate

gy p

roce

ss h

as

deem

ed th

e cle

aran

ce p

roce

ss a

s a

poss

ible

are

a fo

r im

prov

emen

t, Co

nsum

er E

ngag

emen

t has

def

erre

d wo

rk o

n th

is de

liver

able

. O

nce

it is

dete

rmin

ed w

heth

er o

r not

the

proc

ess

will b

e dr

astic

ally

chan

ged,

Con

sum

er E

ngag

emen

t wi

ll eith

er m

ove

forw

ard

with

its d

elive

rabl

e, o

r will

be h

eavil

y in

volve

d in

the

draf

ting

proc

ess.

Low

• If

it is

dete

rmin

ed th

at th

e Cl

eara

nce

Proc

ess

is in

nee

d of

im

prov

emen

t, we

reco

mm

end

cons

ider

atio

ns fo

r a m

ore

stre

amlin

ed a

ppro

ach

to th

e pr

oces

s an

d st

rong

ly en

cour

age

Cons

umer

Eng

agem

ent t

o be

invo

lved

in th

e pr

oces

s of

dev

elop

ing

a ne

w po

licy.

8-10

blo

g po

sts

each

mon

th

gene

rate

d by

the

Enga

gem

ent O

ffice,

plu

s su

ppor

t for

finan

cial e

duca

tion

cont

ent in

pos

t and

tip fo

rm

gene

rate

d by

the

OFE

(in

addi

tion

to p

osts

from

aro

und

the

bure

au)

Cons

umer

Eng

agem

ent h

as c

onsis

tent

ly wo

rked

with

oth

er

offic

es th

roug

hout

CFP

B to

dev

elop

blo

g co

nten

t tha

t sup

ports

br

oade

r out

reac

h ef

forts

to s

take

hold

er g

roup

s (i.

e., c

onsu

mer

ad

voca

cy g

roup

s, s

tude

nts,

ser

vicem

embe

rs, e

tc.).

The

Offic

e is

also

impl

emen

ting

a pi

lot p

rogr

am to

dev

elop

2 to

3 b

log

post

s pe

r wee

k ar

ound

a “C

FPB

in y

our c

omm

unity

” the

me

that

hig

hlig

hts

CFPB

sen

ior l

eade

rshi

p vis

iting

exte

rnal

st

akeh

olde

rs.

Med

ium

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Cons

isten

t pro

mot

ion

of o

ur

mon

ey e

duca

tion

cont

ent

such

as

tip o

f the

day

to o

ther

sit

es/c

hann

els

Whi

le C

onsu

mer

Eng

agem

ent is

wor

king

in c

olla

bora

tion

with

th

e O

ffice

of F

inan

cial E

duca

tion

to p

lan

for p

ostin

g, p

rom

otin

g an

d di

strib

utin

g th

is co

nten

t as

soon

as

it is

avai

labl

e fo

r pu

blica

tion,

som

e of

this

work

will

be d

epen

dent

on

the

deve

lopm

ent o

f the

blu

eprin

t men

tione

d ab

ove.

Med

ium

•

We

reco

mm

end

Cons

umer

Eng

agem

ent c

ontin

ue to

pla

n fo

r th

e pr

omot

ion

of e

duca

tion

cont

ent t

o en

sure

pro

mot

ion

is as

se

amle

ss a

s po

ssib

le o

nce

it is

read

y fo

r pub

licat

ion.

Web

por

tals

for t

he

empo

werm

ent o

ffices

plu

s O

FE (M

y Fi

) and

Fai

r Len

ding

The

Offic

e of

Fai

r Len

ding

and

Equ

al O

ppor

tuni

ty’s

web

porta

l an

d an

impr

oved

site

for t

he O

ffice

of C

omm

unity

Ban

ks a

nd

Cred

it Uni

ons

will l

aunc

h on

Oct

ober

2nd

. An

upd

ated

OSA

we

b po

rtal w

ill be

laun

ched

late

r in

Oct

ober

.

Med

ium

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

One

to tw

o in

itial o

fferin

gs to

en

gage

the

publ

ic on

mon

ey

issue

s or

mon

ey d

ecisi

on-

mak

ing

in c

lose

coo

pera

tion

with

OFE

Th

is de

liver

able

is d

epen

dent

on

the

cons

umer

exp

erie

nce

blue

prin

t out

lined

abo

ve.

High

•

We

reco

mm

end

CFPB

con

tinue

to m

ove

forw

ard

with

the

cons

umer

exp

erie

nce

blue

prin

t so

that

wor

k th

at is

de

pend

ent o

n it c

an m

ove

forw

ard.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

97

Goa

l Sc

ore

Sum

mar

y of

Per

form

ance

Pr

iorit

y F

indi

ng /

Reco

mm

enda

tion

Desig

n an

d im

plem

enta

tion

of

cale

ndar

for u

se o

f dire

ct

emai

l tool

Beca

use

of th

e CF

PB-w

ide

stra

tegy

pro

cess

und

erwa

y, a

n in

terim

stra

tegy

pla

n wa

s pu

t in p

lace

for a

n ed

itoria

l cal

enda

r an

d th

e bu

ildin

g of

targ

eted

list s

egm

ents

. Co

nsum

er

Enga

gem

ent le

d th

e ef

fort

to d

evel

op th

e in

terim

stra

tegy

, and

wi

ll lea

d th

e lo

ng-te

rm p

roce

ss m

ovin

g fo

rwar

d.

Med

ium

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Web

stre

amin

g ca

pacit

y (fo

r O

ct O

SA c

onve

ning

, en

forc

emen

t hea

rings

)

Cons

umer

Eng

agem

ent,

in c

olla

bora

tion

with

the

info

rmat

ion

and

tech

nolo

gy o

ffices

, suc

cess

fully

stre

amed

Raj

Dat

e’s

9/15

Ph

ilade

lphi

a sp

eech

live

on th

e CF

PB w

ebsit

e. P

lans

to liv

e st

ream

two

mor

e ev

ents

this

mon

th a

re in

pla

ce.

Med

ium

•

We

enco

urag

e CF

PB to

con

tinue

to u

se liv

e st

ream

ing

as a

co

mm

unica

tions

tool

, as

it allo

ws th

ose

who

are

unab

le to

at

tend

CFP

B ev

ents

the

oppo

rtuni

ty to

be

a pa

rt of

them

.

Deve

lop

milit

ary

cont

ent f

or

webs

ite/s

ocia

l med

ia

OSA

has

dev

elop

ed n

umer

ous

sour

ces

of w

eb c

onte

nt,

inclu

ding

a s

pecif

ic la

ndin

g pa

ge o

n th

e CF

PB w

ebsit

e fo

r se

rvice

mem

bers

that

hig

hlig

hts

who

OSA

is a

nd w

hat t

hey

are

doin

g fo

r mem

bers

of t

he m

ilitar

y an

d th

eir f

amilie

s, a

nd

num

erou

s bl

og p

osts

and

arti

cles

rega

rdin

g th

e ha

ppen

ings

in

side

OSA

and

the

even

ts, s

peec

hes,

etc

. tha

t Hol

ly Pe

traeu

s ha

s pa

rticip

ated

in.

Med

ium

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Host

con

veni

ng in

Oct

ober

co

ncer

ning

bes

t pra

ctice

s in

of

ferin

g fin

ancia

l pro

duct

s to

m

ilitar

y

OSA

has

rele

ased

a R

eque

st fo

r Inf

orm

atio

n via

the

Fede

ral

Regi

ster

to g

ain

insig

ht o

n th

e pr

oduc

ts a

nd s

ervic

es th

at a

re

mos

t uni

que

to s

ervic

emem

bers

and

thei

r fam

ilies.

An

orig

inal

O

ctob

er c

onve

ning

dat

e wa

s m

oved

to N

ovem

ber d

ue to

lo

gist

ical c

onflic

ts w

ith S

tude

nt a

nd O

lder

Am

erica

n ro

llout

ev

ents

. Pl

anni

ng is

wel

l und

erwa

y fo

r the

Nov

embe

r eve

nt,

thou

gh th

at d

ate

may

be

mov

ed b

ack

as to

avo

id a

con

flict w

ith

Pres

iden

t Oba

ma’

s Fi

nanc

ial E

duca

tion

Sum

mit.

Pla

nnin

g th

us fa

r has

inclu

ded

iden

tifyin

g pa

nel s

peak

ers,

cre

atin

g qu

estio

n se

ts, a

nd fig

urin

g ou

t logi

stica

l info

rmat

ion.

Med

ium

•

We

reco

mm

end

the

CFPB

con

tinue

the

plan

ning

pro

cess

al

read

y un

derw

ay fo

r the

con

veni

ng e

vent

.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

98

Goa

l Sc

ore

Sum

mar

y of

Per

form

ance

Pr

iorit

y F

indi

ng /

Reco

mm

enda

tion

Eval

uate

finan

cial e

duca

tion

at m

ilitar

y ba

sic tr

aini

ng

Mem

bers

of O

SA h

ave

visite

d ba

sic tr

aini

ng s

ites

of tw

o m

ilitar

y di

visio

ns: t

he N

avy

and

Mar

ine

Corp

s. O

SA is

sch

edul

ed to

vis

it the

bas

ic tra

inin

g sit

e fo

r the

Arm

y at

For

t Jac

kson

on

Nove

mbe

r 4, 2

011.

Visi

ts to

the

Air F

orce

and

Coa

st G

uard

ba

sic tr

aini

ng s

ites

are

curre

ntly

bein

g sc

hedu

led.

So

far,

OSA

ha

s m

ade

only

initia

l obs

erva

tions

, but

wan

t to

focu

s on

the

begi

nnin

g of

milit

ary

care

ers

and

the

use

of te

chno

logy

to

mod

erni

ze fin

ancia

l edu

catio

n fo

r new

mem

bers

of t

he m

ilitar

y.

Med

ium

• W

e re

com

men

d th

e CF

PB c

ontin

ue to

mov

e fo

rwar

d wi

th

plan

ning

visi

ts to

the

rem

aini

ng m

ilitar

y ba

sic tr

aini

ng s

ites

in

orde

r to

reac

h its

goa

l of g

oing

to a

ll milit

ary

divis

ion

basic

tra

inin

g sit

es b

y Ja

nuar

y 20

12.

Deve

lop

revis

ed c

urric

ulum

fo

r new

recr

uits

in

coor

dina

tion

with

Dep

t. of

De

fens

e

The

deve

lopm

ent o

f rev

ised

curri

culu

m fo

r new

recr

uits

is

unde

rway

with

DoD

; OSA

is in

a d

ata-

gath

erin

g ph

ase.

In

itial o

bser

vatio

ns s

how

a va

rianc

e am

ong

curri

culu

ms

acro

ss

milit

ary

divis

ions

.

Med

ium

•

We

reco

mm

end

the

CFPB

con

tinue

its w

ork

with

DoD

mov

e fo

rwar

d wi

th b

egin

ning

to re

vise

new

recr

uit c

urric

ulum

.

Prov

ide

milit

ary

expe

rtise

for

Cons

umer

Res

pons

e: s

crip

ts,

FAQ

s, re

ferra

ls, ta

ilore

d as

sista

nce

All C

onsu

mer

Res

pons

e sc

ripts

, FAQ

s, re

ferra

ls, a

nd ta

ilore

d as

sista

nce

with

resp

ect t

o se

rvice

mem

bers

hav

e be

en

deve

lope

d wi

th e

xten

sive

OSA

inpu

t. M

ediu

m

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce e

lem

ent

Raise

awa

rene

ss o

f CF

PB/O

SA th

roug

h m

edia

, sp

eech

es a

nd o

utre

ach

to

busin

ess

and

gove

rnm

ent

CFPB

and

OSA

hav

e bo

th e

xten

sivel

y us

ed C

FPB’

s bl

og to

di

ssem

inat

e in

form

atio

n re

gard

ing

the

happ

enin

gs in

the

Bure

au a

s a

whol

e an

d O

SA.

Both

hav

e us

ed th

e bl

og to

in

form

the

publ

ic on

spe

eche

s an

d ev

ents

that

hav

e ta

ken

plac

e, a

s we

ll as

aske

d fo

r the

pub

lic’s

inpu

t on

mul

tiple

issu

es.

Holly

Pet

raeu

s ha

s pa

rticip

ated

in 2

6 m

eetin

gs a

nd s

peec

hes

since

her

app

oint

men

t as

Dire

ctor

of O

SA in

Jan

uary

201

1.

Exam

ples

of g

roup

s sh

e ha

s sp

oken

to in

clude

wou

nded

so

ldie

rs a

t Wal

ter R

eed

Natio

nal M

ilitar

y M

edica

l Cen

ter,

the

Asso

ciatio

n of

Milit

ary

Bank

s, th

e Ar

my

JAG

Sch

ool, t

he

Wou

nded

War

riors

pro

ject

, and

mem

bers

of t

he U

.S. H

ouse

an

d Se

nate

. M

embe

rs o

f the

OSA

team

hav

e he

ld n

umer

ous

town

halls

and

roun

dtab

les

and

trave

led

to m

ilitar

y ba

ses

acro

ss th

e co

untry

to c

reat

e a

feed

back

loop

thro

ugh

which

O

SA c

an e

duca

te m

embe

rs o

f the

milit

ary

on w

hat is

goi

ng o

n in

side

the

offic

e an

d O

SA c

an le

arn

from

milit

ary

mem

bers

wh

at is

sues

are

the

mos

t impo

rtant

to th

em.

Med

ium

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

99

Tab

le 2

3: A

lign

men

t w

ith

Per

form

ance

Sta

nd

ard

s (A

ud

ien

ces)

Audi

ence

Sc

ore

Sum

mar

y of

Per

form

ance

Pr

iorit

y F

indi

ng /

Reco

mm

enda

tion

Cons

umer

s

As a

con

sum

er-fo

cuse

d or

gani

zatio

n, th

e CF

PB h

as u

nder

stan

dabl

y m

ade

cons

umer

s th

eir p

riorit

y au

dien

ce. C

FPB’

s we

bsite

is u

ser-

frien

dly

both

in n

avig

atio

n an

d in

con

tent

acc

essib

ility

and

unde

rsta

ndin

g. M

oreo

ver,

the

CFPB

has

a g

ood

stra

tegy

in b

uild

ing

rela

tions

hips

with

gro

ups

that

ser

ve a

s a

cond

uit t

o re

achi

ng

cons

umer

s. F

inal

ly, it

is de

velo

ping

a p

aral

lel ta

rget

ed a

ppro

ach

to

reac

h co

nsum

ers

with

uni

que

need

s or

circ

umst

ance

s (e

.g.,

serv

icem

embe

rs, e

thni

c gr

oups

). Th

e we

bsite

and

med

ia a

s co

mm

unica

tions

veh

icles

hav

e lim

itatio

ns, p

artic

ular

ly fo

r rur

al a

nd

low-

inco

me

popu

latio

ns.

CFPB

has

atte

mpt

ed to

alle

viate

this

by

cond

uctin

g to

wnha

lls in

low-

inco

me

area

s, in

cludi

ng e

vent

s in

Ohi

o,

Mon

tana

and

San

Fra

ncisc

o. G

iven

the

spec

ial c

halle

nges

with

en

gagi

ng th

ese

grou

ps, c

oord

inat

ion

betw

een

depa

rtmen

ts w

ithin

Ex

tern

al A

ffairs

to le

vera

ge re

latio

nshi

ps w

ith th

ird-p

arty

gro

ups

is an

d wi

ll con

tinue

to b

e im

porta

nt g

oing

forw

ard.

Th

e bu

reau

has

also

em

brac

ed th

e im

porta

nce

of p

rovid

ing

mul

ti-lin

gual

ser

vices

, co-

deve

lopi

ng (n

ot tr

ansla

ting)

the

reva

mpe

d m

ortg

age

disc

losu

re

docu

men

ts fr

om K

now

Befo

re Y

ou O

we fo

r Spa

nish

use

. A

fully

fu

nctio

nal S

pani

sh w

ebsit

e is

also

in d

evel

opm

ent.

The

CFPB

’s 80

0 nu

mbe

r is

avai

labl

e in

189

lang

uage

s, a

nd th

ey w

ere

the

first

fede

ral

bure

au to

twee

t in S

pani

sh. O

f the

419

in-p

erso

n m

eetin

gs E

lizab

eth

War

ren

cond

ucte

d wi

th v

ario

us g

roup

s, m

ore

19%

wer

e wi

th

cons

umer

gro

ups.

High

• Ad

ding

add

itiona

l lang

uage

s to

the

webs

ite a

nd g

ener

atin

g se

lect

m

ater

ials

in o

ther

lang

uage

s wi

ll allo

w th

e CF

PB to

eng

age

cons

umer

s in

pop

ulat

ions

it ca

n on

ly re

ach

indi

rect

ly at

this

poin

t in

time.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

100

Audi

ence

Sc

ore

Sum

mar

y of

Per

form

ance

Pr

iorit

y F

indi

ng /

Reco

mm

enda

tion

Polic

ymak

ers

CFPB

’s O

ffice

of L

egisl

ative

Affa

irs h

as c

omm

unica

ted

regu

larly

sin

ce it

bega

n its

wor

k wi

th fe

dera

l pol

icym

aker

s by

dev

elop

ing

repo

rts o

n th

e CF

PB’s

prog

ress

, pro

vidin

g te

stim

ony

and

regu

lar p

hone

cal

ls to

kee

p M

embe

rs o

f Con

gres

s in

form

ed o

n iss

ues

and

initia

tives

. Ph

one

calls

pr

ior t

o a

maj

or a

nnou

ncem

ent f

rom

the

CFPB

to S

enat

e Ba

nkin

g an

d Ho

use

Fina

ncia

l Ser

vices

com

mitte

es e

nsur

e no

sur

prise

s fo

r la

wmak

ers.

Eliz

abet

h W

arre

n te

stifie

d be

fore

Con

gres

s on

thre

e oc

casio

ns in

201

1 to

pro

vide

upda

tes

on C

FPB

in M

arch

, May

and

Ju

ly. C

FPB

offic

ials

have

test

ified

a to

tal o

f 11

times

bef

ore

Cong

ress

th

us fa

r in

2011

to p

rovid

e up

date

s. A

lso, in

add

ition

to

Mem

oran

dum

s of

Und

erst

andi

ng (M

OU’

s) in

pla

ce w

ith s

tate

atto

rney

ge

nera

ls, m

eetin

gs h

ave

take

n pl

ace

inclu

ding

one

mee

ting

with

sta

te

AGs

that

inclu

ded

mem

bers

of C

FPB

staf

f fro

m e

very

divi

sion.

Of t

he

419

in-p

erso

n m

eetin

gs E

lizab

eth

War

ren

cond

ucte

d wi

th v

ario

us

grou

ps, m

ore

than

a q

uarte

r (26

%) w

ere

on th

e Hi

ll.

Med

ium

• Th

e In

terg

ov o

ffice

was

rece

ntly

staf

fed,

and

will

be re

spon

sible

fo

r dev

elop

ing

rela

tions

hips

with

sta

te, lo

cal a

nd in

tern

atio

nal

offic

ials.

Ful

l func

tiona

lity o

f thi

s of

fice

will f

urth

er e

nhan

ce th

e ab

ility

for t

he C

FPB

to d

emon

stra

te its

sup

port

and

impa

ct a

nd

also

to s

olici

t info

rmat

ion

at th

e st

ate

and

loca

l leve

l.

Priva

te S

ecto

r

In th

e ea

rly s

tage

s of

the

CFPB

, Eliz

abet

h W

arre

n m

ade

pers

onal

cal

ls to

lead

ers

of th

e na

tion’

s la

rges

t ban

ks, a

nd m

et w

ith le

ader

s of

thos

e ba

nks

when

ever

sch

edul

es a

llowe

d tra

vel to

New

Yor

k Ci

ty.

Prio

r to

the

CFPB

Pro

gres

s Re

port

rele

ase

in J

uly,

the

sam

e le

ader

s we

re

mad

e aw

are

of th

e co

min

g re

port.

The

ope

ratio

n to

eng

age

larg

e pa

rticip

ants

is s

till b

eing

def

ined

give

n th

at: (

1) s

uper

visor

y in

tera

ctio

n pr

ovid

es a

nat

ural

con

duit f

or c

omm

unica

tion;

and

(2) t

he A

dviso

ry

Boar

d wi

ll hel

p sh

ape

what

this

even

tual

ly lo

oks

like.

How

ever

, CFP

B ha

s de

velo

ped

an o

ngoi

ng d

ialo

gue

with

com

mun

ity b

anks

thro

ugh

dire

ct o

utre

ach,

and

trad

e gr

oups

suc

h as

ICBA

and

ABA

. Of t

he 4

19

in-p

erso

n m

eetin

gs E

lizab

eth

War

ren

cond

ucte

d wi

th v

ario

us g

roup

s,

near

ly ha

lf (47

%) w

ere

with

finan

cial s

ervic

es fir

ms,

com

mun

ity b

anks

an

d cr

edit u

nion

s.

Med

ium

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

101

Audi

ence

Sc

ore

Sum

mar

y of

Per

form

ance

Pr

iorit

y F

indi

ng /

Reco

mm

enda

tion

Third

Par

ty

Org

aniza

tions

CFPB

’s co

nsum

er fo

cus

has

mad

e in

tera

ctio

ns w

ith th

ird p

artie

s,

parti

cula

rly c

onsu

mer

gro

ups,

a p

riorit

y. T

hey

have

em

brac

ed th

e ne

ed to

kee

p an

ope

n lin

e of

com

mun

icatio

n wi

th k

ey th

ird p

arty

gr

oups

(e.g

., Co

nsum

ers

Unio

n an

d Am

erica

ns fo

r Fin

ancia

l Ref

orm

). W

hile

the

CFPB

’s in

tent

ions

in th

is ar

ea a

re a

dvan

ced

base

d on

co

nver

satio

ns w

ith s

taff,

mor

e do

cum

ente

d pl

anni

ng w

ould

be

usef

ul

parti

cula

rly a

s ot

her d

epar

tmen

ts lo

ok to

leve

rage

third

par

ty

tract

ion/

awar

enes

s an

d th

us m

axim

ize s

ourc

es. C

FPB

has

reco

gnize

d th

e ne

ed to

tailo

r the

ir se

rvice

s to

sel

ect E

nglis

h-se

cond

la

ngua

ge p

opul

atio

ns w

ho h

ave

been

par

ticul

arly

affe

cted

by

the

finan

cial c

risis.

The

CFP

B’s

800

num

ber i

s av

aila

ble

in 1

89

lang

uage

s, a

nd th

ey w

ere

the

first

fede

ral b

urea

u to

twee

t in S

pani

sh.

High

• W

e re

com

men

d m

ore

docu

men

ted

plan

ning

so

that

the

CFP

B ca

n ou

tline

key

targ

et g

roup

s, a

sses

s th

ose

rela

tions

hips

and

ot

her d

epar

tmen

ts w

ithin

the

CFPB

can

leve

rage

third

par

ty

tract

ion/

awar

enes

s as

wel

l.

Med

ia

Med

ia is

an

impo

rtant

aud

ienc

e fo

r the

CFP

B gi

ven

that

it is

ofte

n th

e wa

y co

nsum

ers

lear

n ab

out t

he b

urea

u. T

he C

FPB

has

crea

ted

the

Med

ia R

elat

ions

offic

e an

d pl

aced

a p

rem

ium

of b

eing

act

ive in

this

area

, whi

ch re

sults

sug

gest

has

pai

d of

f. F

eedb

ack

from

repo

rters

we

spok

e wi

th in

dica

te th

at C

FPB

staf

f are

resp

onsiv

e an

d in

form

ed.

Med

ium

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

102

Tab

le 2

4: A

lign

men

t w

ith

Per

form

ance

Sta

nd

ard

s (P

olic

ies

and

Pro

cess

es)

Polic

y / P

roce

ss

Scor

e Su

mm

ary

of P

erfo

rman

ce

Prio

rity

Reco

mm

enda

tions

Clea

ranc

e Pr

oces

s

CFPB

dev

elop

ed a

nd d

istrib

utes

to a

ll new

em

ploy

ees

a po

licy

docu

men

t tha

t out

lines

am

ong

othe

r thi

ngs

the

clear

ance

pro

cess

. It in

clude

s th

e pr

oces

s al

l sta

ff sh

ould

us

e fo

r int

erna

l and

ext

erna

l doc

umen

ts in

cludi

ng

mai

ntai

ning

reco

rds

of th

e do

cum

ents

as

well a

s de

tail

abou

t doc

umen

t typ

e an

d ap

prop

riate

timel

ines

for i

nter

nal

revie

w an

d ap

prov

al.

Low

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce e

lem

ent

Mor

ning

Mee

ting

– Ex

tern

al

Com

mun

icato

rs

A m

orni

ng m

eetin

g wi

th a

ll ext

erna

l com

mun

icato

rs e

nsur

es

that

the

CFPB

is s

peak

ing

with

one

voi

ce, a

nd th

at a

ll m

embe

rs o

f the

team

are

on

the

sam

e pa

ge.

Low

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce e

lem

ent

FOIA

Pro

cess

FOIA

is a

requ

ired

com

pone

nt fo

r cre

atin

g tra

nspa

renc

y wi

th th

e pu

blic.

CFP

B ha

s es

tabl

ished

and

impl

emen

ted

a FO

IA p

roce

ss th

at is

exp

lain

ed c

lear

ly an

d th

orou

ghly

on

the

webs

ite fo

r int

eres

ted

parti

es. I

nter

nally

, the

pro

cess

has

be

en c

lear

ly de

fined

usin

g a

proc

ess

map

that

out

lines

im

porta

nt p

oint

s of

dec

ision

-mak

ing

with

in th

e CF

PB, a

pr

oces

sing

mod

el c

heck

list,

and

timel

ine

that

inclu

des

actio

n ite

ms,

goa

ls an

d co

mpl

etio

n da

te. T

he C

FPB

has

plac

ed a

n em

phas

is he

re a

nd it’

s ap

pare

nt. W

ith th

e im

plem

enta

tion

of th

e eF

OIA

sys

tem

, item

s su

ch a

s a

read

ing

room

, FO

IA p

olicy

and

con

sum

er g

uide

may

be

adde

d.

High

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Wee

kly F

OIA

Upd

ate

with

Inte

rnal

St

akeh

olde

rs

(Awa

rene

ss M

eetin

g)

Wee

kly u

pdat

es o

n th

e FO

IA p

roce

ss p

rovid

e in

tern

al

cont

rol a

nd e

nsur

e th

at th

e ap

prop

riate

peo

ple

are

mad

e aw

are

of la

rge

or p

oten

tially

sen

sitive

requ

ests

that

hav

e be

en m

ade.

It a

lso h

ighl

ight

s iss

ues

that

may

(or m

ay n

ot)

be g

aini

ng m

omen

tum

am

ong

the

publ

ic.

Low

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce e

lem

ent

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

103

Polic

y / P

roce

ss

Scor

e Su

mm

ary

of P

erfo

rman

ce

Prio

rity

Reco

mm

enda

tions

Med

ia M

emo

A m

edia

mem

o is

dist

ribut

ed to

all e

mpl

oyee

s at

orie

ntat

ion

that

out

lines

how

to d

eal w

ith m

edia

requ

ests

and

who

is

appr

oved

to s

peak

on

beha

lf of t

he C

FPB.

Thi

s se

rves

to

avoi

d in

stan

ces

wher

e st

atem

ents

to th

e m

edia

are

mad

e by

som

eone

not

aut

horiz

ed to

do

so, a

nd o

utlin

es th

e in

tern

al s

yste

m in

pla

ce to

app

ropr

iate

ly ha

ndle

an

impo

rtant

aud

ienc

e an

d ve

hicle

for t

he C

FPB.

Low

• No

reco

mm

enda

tions

pro

vided

for t

his

perfo

rman

ce e

lem

ent

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

104

Tab

le 2

5: A

lign

men

t w

ith

Per

form

ance

Sta

nd

ard

s (M

essa

ges)

Stra

tegy

/Mes

sage

Sc

ore

Sum

mar

y of

Per

form

ance

Pr

iorit

y Re

com

men

datio

ns

The

CFPB

Mes

sage

The

CFPB

dev

elop

ed a

doc

umen

t in D

ecem

ber 2

010

calle

d Th

e CF

PB M

essa

ge th

at a

rticu

late

s th

e CF

PB’s

valu

e pr

opos

ition

for c

onsu

mer

s. H

owev

er, n

o ad

ditio

nal

mat

eria

l has

bee

n de

velo

ped

with

resp

ect t

o co

mm

unica

tions

mes

sage

s.

High

• W

hile

thou

ghtfu

l con

sider

atio

n of

the

CFPB

’s va

lue

prop

ositio

n fo

r co

nsum

ers

is wo

rthwh

ile, t

he C

FPB

shou

ld d

evel

op a

mes

sage

ar

chite

ctur

e th

at c

onsid

ers

the

spec

ific n

eeds

of a

ll of it

s au

dien

ces

(con

sum

ers,

indu

stry

, pol

icym

aker

s, e

tc.).

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

105

Tab

le 2

6: A

lign

men

t w

ith

Per

form

ance

Sta

nd

ard

s (V

ehic

les

and

Mat

eria

ls)

Vehi

cle

/ Mat

eria

l Sc

ore

Sum

mar

y of

Per

form

ance

Pr

iorit

y Re

com

men

datio

ns

CFPB

Web

site

The

CFPB

’s we

bsite

is a

n im

porta

nt fo

rm o

f com

mun

icatio

n wi

th th

e pu

blic

for t

he C

FPB.

The

web

site

is ea

sy to

na

vigat

e an

d de

liber

atel

y ea

sy to

read

(dev

elop

ed ta

rget

ing

an 8

th g

rade

read

ing

leve

l). I

t also

inclu

des

info

rmat

ion

on

what

has

bee

n go

ing

on in

the

bure

au (s

ee b

elow

), in

cludi

ng

Requ

ests

for C

omm

ent a

nd in

form

atio

n on

thei

r rec

ent

proj

ects

(e.g

., Kn

ow B

efor

e Yo

u O

we a

nd C

FPB’

s re

port

on

rem

ittanc

es).

It is

impo

rtant

to k

eep

in m

ind

that

the

web

only

reac

hes

a se

lect

por

tion

of th

e po

pula

tion

and

as s

uch,

not

fa

ll pre

y to

ass

umin

g if i

t’s o

n th

e we

b, it’

s re

achi

ng p

eopl

e.

Med

ium

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

CFPB

Blo

g

The

CFPB

blo

g, w

ithin

the

webs

ite, s

erve

s as

a v

ehicl

e fo

r co

mm

unica

ting

what

CFP

B is

doin

g as

a b

urea

u. I

t also

se

rves

as

a wa

y fo

r CFP

B to

resp

ond

to c

onsu

mer

inqu

iries

and

the

issue

s th

at th

ey b

elie

ve a

re m

ost im

porta

nt (e

.g.,

a Tw

itter p

ost h

ighl

ight

ed in

a J

uly

15, 2

011

by Th

e New

York

Tim

es o

n m

ortg

age

disc

losu

re fo

rms

that

the

bure

au

resp

onde

d to

via

a v

ideo

pos

t on

its b

log)

.

Low

• As

the

orga

niza

tion

mat

ures

and

the

staf

f gro

ws, C

FPB

shou

ld s

trive

to

incr

ease

the

frequ

ency

of b

log

post

s (c

urre

ntly

abou

t one

per

wee

k), in

or

der t

o m

ake

this

a m

ore

robu

st c

omm

unica

tions

tool

.

Even

ts/S

peec

hes

CFPB

eve

nts/

spee

ches

give

a fa

ce to

the

bure

au, s

howi

ng

cons

umer

s th

e le

ader

s of

the

orga

niza

tion

and

prov

idin

g a

chan

ce to

furth

er c

omm

unica

te th

e m

essa

ge a

nd p

rogr

ess

of th

e CF

PB. L

ocal

town

hal

l eve

nts

and

spee

ches

are

a

regu

lar f

orm

of c

omm

unica

tion

at C

FPB.

Live

stre

amin

g an

d po

stin

g vid

eos

of s

peec

hes/

even

ts o

n th

e we

bsite

pro

vide

an a

dditio

nal w

ay fo

r peo

ple

who

coul

d no

t atte

nd th

e ev

ent

to b

e in

clude

d (e

.g.,

lives

tream

ing

of R

aj D

ate’

s sp

eech

in

Phila

delp

hia

on S

epte

mbe

r 15,

201

1).

Med

ium

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

106

Vehi

cle

/ Mat

eria

l Sc

ore

Sum

mar

y of

Per

form

ance

Pr

iorit

y Re

com

men

datio

ns

Pres

s

The

pres

s is

both

an

audi

ence

unt

o its

elf a

s we

ll as

a ve

hicle

to

reac

h ot

her a

udie

nces

. Bas

ed o

n a

med

ia s

can

of to

p-tie

r m

edia

, the

CFP

B ha

s be

en e

ffect

ive in

usin

g th

e pr

ess

as a

ve

hicle

to g

et its

mes

sage

out

. O

f par

ticul

ar n

ote

are

a nu

mbe

r of p

iece

s wr

itten

spec

ifical

ly on

CFP

B th

at p

rovid

e up

date

s on

the

CFPB

’s op

erat

ions

, pra

ise in

itiativ

es o

f the

bu

reau

(i.e

., Kn

ow B

efor

e Yo

u O

we),

or h

ighl

ight

its

inte

ract

ion

with

the

publ

ic.

Med

ium

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Web

inar

s/Li

vest

ream

CFPB

has

follo

wed

thro

ugh

on p

lans

to u

se w

ebin

ars

to

gene

rate

a d

ialo

gue

betw

een

the

bure

au a

nd o

utsid

e gr

oups

, inclu

ding

with

com

mun

ity b

anks

, larg

e tra

de

asso

ciatio

ns, la

rge

cred

it car

d iss

uers

, cre

dit u

nion

s, a

nd

cons

umer

and

civi

l rig

hts

grou

ps.

The

CFPB

also

su

cces

sful

ly ha

d its

first

lives

tream

of a

n ev

ent o

n 9/

15/2

011

when

Raj

Dat

e’s

spee

ch in

Phi

lade

lphi

a wa

s st

ream

ed liv

e on

CFP

B’s

webs

ite.

Low

• To

dat

e th

ere

has

been

limite

d us

e of

Web

inar

s an

d Li

vest

ream

but

the

CFPB

has

hon

ored

its c

omm

itmen

t to

use

them

as

a wa

y of

co

mm

unica

tions

with

the

gene

ral p

ublic

or a

llowi

ng th

em to

par

ticip

ate

in

an e

vent

. As

the

staf

f gro

ws a

nd C

FPB

host

s/pa

rticip

ates

in m

ore

even

ts, t

his

mig

ht b

ecom

e a

mor

e ro

bust

com

mun

icatio

ns to

ol.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

107

Tab

le 2

7: A

lign

men

t w

ith

Per

form

ance

Sta

nd

ard

s (M

etri

cs o

f S

ucc

ess)

Met

ric

Scor

e Su

mm

ary

of P

erfo

rman

ce

Prio

rity

Find

ing

/ Rec

omm

enda

tion

Defin

ition

of

Com

mun

icatio

ns/M

edia

Su

cces

s

Broa

dly

the

CFPB

com

mun

icatio

ns s

taff

views

suc

cess

as

effe

ctive

ly co

mm

unica

ting

the

purp

ose

of th

e CF

PB to

co

nsum

ers.

How

ever

, diffe

rent

def

initio

ns o

f suc

cess

ex

ist a

cros

s de

partm

ents

(i.e

., on

e di

visio

n m

ay b

ase

succ

ess

on th

e nu

mbe

r of c

omm

ents

rece

ived

while

an

othe

r may

bel

ieve

suc

cess

is w

heth

er e

very

med

ia

stor

y th

at is

pitc

hed

gets

prin

ted)

. In

othe

r cas

es, t

here

are

no

def

ined

met

rics

at a

ll or t

he g

oals

that

hav

e be

en

esta

blish

ed a

re n

ot m

easu

rabl

e. M

etric

s ar

e a

chal

leng

e in

com

mun

icatio

ns a

nd u

nder

stan

dabl

y th

e CF

PB h

as

been

in a

mor

e ta

ctica

l/sur

vival

mod

e sin

ce its

cre

atio

n.

High

• As

add

itiona

l sta

ff is

adde

d, d

evot

ing

time

and

reso

urce

s to

def

ine

succ

ess

and

esta

blish

met

rics

will a

llow

the

CFPB

to e

valu

ate

itsel

f and

fo

r oth

ers

outs

ide

the

CFPB

to d

o th

e sa

me.

Also

, as

the

staf

f will

inev

itabl

y ex

perie

nce

som

e tu

rnov

er, h

avin

g do

cum

ente

d m

etric

s fo

r as

sess

ing

perfo

rman

ce is

impo

rtant

.

Wer

e ke

y st

akeh

olde

rs

enga

ged

in th

e im

plem

enta

tion

perio

d?

As d

iscus

sed

in e

arlie

r ass

essm

ents

of k

ey a

udie

nce

outre

ach,

CFP

B ha

s cle

arly

mad

e co

nsum

ers

thei

r prio

rity

audi

ence

. Th

roug

hout

the

impl

emen

tatio

n pe

riod,

co

nsum

ers

(and

third

par

ty g

roup

s) w

ere

enga

ged

thro

ugh

mul

tiple

med

ium

s, in

cludi

ng th

roug

h th

e CF

PB’s

webs

ite a

nd th

roug

h in

itiativ

es lik

e Kn

ow B

efor

e Yo

u O

we

and

the

larg

er p

artic

ipan

t Req

uest

for C

omm

ent.

Thr

ough

th

e O

ffice

of C

omm

unity

Affa

irs, c

onsu

mer

gro

ups

were

to

uche

d on

a c

onsis

tent

bas

is, w

heth

er it

was

thro

ugh

back

cha

nnel

s, o

r thr

ough

par

ticip

atio

n in

town

halls

and

ot

her C

FPB

even

ts.

Polic

ymak

ers

were

also

eng

aged

th

roug

hout

the

impl

emen

tatio

n pe

riod,

par

ticul

arly

thro

ugh

Hill b

riefin

gs a

nd te

stim

ony

by C

FPB

pers

onne

l. Hi

ll sta

ff we

re a

lso in

clude

d in

num

erou

s CF

PB e

vent

s, in

cludi

ng

pre-

brie

fing

calls

bef

ore

the

July

21st l

aunc

h, a

mor

tgag

e di

sclo

sure

sym

posiu

m, a

nd a

n ev

ent f

ocus

ed o

n th

e CA

RD A

ct.

As th

e CF

PB’s

work

with

ICBA

exh

ibits

, the

pr

ivate

sec

tor w

as a

lso e

ngag

ed th

roug

hout

the

impl

emen

tatio

n pe

riod.

Eliz

abet

h W

arre

n at

tend

ed m

any

mee

tings

and

hel

d m

any

phon

e ca

lls w

ith m

embe

rs o

f the

fin

ancia

l indu

stry

.

High

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

108

Met

ric

Scor

e Su

mm

ary

of P

erfo

rman

ce

Prio

rity

Find

ing

/ Rec

omm

enda

tion

Does

the

publ

ic kn

ow

abou

t CFP

B an

d ho

w to

fin

d th

e bu

reau

?

CFPB

has

mad

e a

cons

cious

effo

rt to

eng

age

the

publ

ic in

the

work

per

form

ed b

y th

e CF

PB.

Whi

le s

ucce

ss is

di

fficul

t to

defin

e at

this

early

sta

ge, C

FPB

has

an

enga

ged

com

mun

ity a

ctive

ly ut

ilizin

g th

e we

bsite

, and

the

bure

au im

pres

sivel

y re

ceive

d ov

er 1

0,00

0 co

nsum

er

resp

onse

s fro

m th

e fir

st ite

ratio

n of

Kno

w Be

fore

You

O

we. I

t is im

porta

nt to

not

e th

at C

FPB

cons

cious

ly ch

ose

not t

o do

a la

rge

rollo

ut in

Jul

y an

d th

ey c

aref

ully

weig

hed

the

trade

off b

etwe

en p

rovid

ing

early

awa

rene

ss b

ut n

ot

bein

g ab

le to

del

iver o

n ce

rtain

pro

mise

s an

d wa

iting

until

CFPB

has

the

capa

city,

bot

h pe

rson

nel w

ise a

nd

stat

utor

ily, t

o de

liver

on

prom

ises

mad

e.

Med

ium

• M

akin

g th

e pu

blic

awar

e of

the

CFPB

is a

size

able

task

and

thus

, it h

as

just

beg

un to

scr

atch

the

surfa

ce in

this

area

. W

e do

not

hav

e an

y re

com

men

datio

ns a

t thi

s tim

e be

yond

wha

t the

CFP

B is

alre

ady

doin

g in

th

is ar

ea. H

owev

er, t

he C

FPB

shou

ld c

onsid

er m

akin

g pu

blic

the

man

y wa

ys it

tries

to re

ach

the

publ

ic an

d as

k fo

r new

s wa

ys it

shou

ld c

onsid

er

via th

e we

bsite

, soc

ial m

edia

, etc

.

Com

mun

ity B

anke

rs fr

om

all 5

0 St

ates

Even

bef

ore

the

offic

ial o

peni

ng d

ate

of C

FPB,

the

bure

au

set a

n am

bitio

us g

oal fo

r mee

ting

with

com

mun

ity

bank

ers

from

all 5

0 st

ates

. Th

e go

al w

as m

ade

publ

ic via

th

e CF

PB’s

webs

ite, h

oldi

ng C

FPB

acco

unta

ble

to th

e pu

blic.

By

reac

hing

out

dire

ctly

and

thro

ugh

third

par

ty

grou

ps s

uch

as th

e IC

BA a

nd A

BA, C

FPB

was

able

to

mee

t the

ir go

al. T

he c

omm

unity

ban

kers

are

an

impo

rtant

gr

oup

for C

FPB

to e

ngag

e as

they

hav

e di

ffere

nt n

eeds

th

an th

e la

rger

par

ticip

ants

do.

If e

ngag

ed p

rope

rly, t

hey

coul

d se

rve

as a

n ad

voca

te fo

r the

CFP

B’s

work

ove

r tim

e.

High

•

No re

com

men

datio

ns p

rovid

ed fo

r thi

s pe

rform

ance

ele

men

t


109

Section 6: Budget

6.1 Scope of Audit

This section establishes the scope of our performance audit in the Budget area. The purpose of this assessment was to evaluate the CFPB’s budgeting processes and their strategic use of the budget, and to make recommendations on how these practices could be more effective and efficient for the organization. In order to evaluate CFPB’s performance, we examined the extent to which the bureau has: (1) complied with relevant laws and regulations; (2) achieved organizational goals and objectives; and (3) aligned with performance standards and best practices. In order to evaluate CFPB’s performance against relevant laws and regulations, we examined the extent to which the bureau has complied with applicable sections of the Dodd-Frank Act, as amended by the Full-Year Continuing Appropriations Act of 2011. In particular, we focused on the following areas:

Applicable language under Title X of the Dodd-Frank Act in order to understand the mechanism by which CFPB requests funding from and is funded by the Board of Governors of the Federal Reserve System

CFPB’s budget formulation and operations planning process including the parties involved; the processes, methods and tools being used; and the timing of budgeting processes

CFPB’s budget execution process including the tracking and reporting of commitments and outlays as well as the related set of reporting responsibilities

CFPB’s financial management systems, the preparation of the bureau financial statements and related assertion as to the effectiveness of internal controls, and planned financial audit of the bureau by the GAO

In order to assess achievement of organizational goals, we held a series of meetings with CFPB officials in the Office of the Chief Operating Officer and the Office of the Chief Financial Officer. In addition, we reviewed documents provided by CFPB related to strategic and operational planning, budget formulation and execution, budgeting policies and procedures, contractual agreements, funding requests of and transfers from the Federal Reserve, and expenditure analysis. We also evaluated whether CFPB budget execution activities provide effective and timely communication to appropriate parties within CFPB management and the public.

With respect to performance standards and best practices for budgeting, financial management and performance management, we principally referenced the guidance in OMB Circular A-11 Preparation, Submission, and Execution of the Budget; OMB Circular A-136, Financial Reporting Requirements; and OMB Circular A-123, Management’s Responsibility for Internal Control. We also referenced the Government Performance and Results Act (GPRA) Modernization Act of 2010 (Public Law 111-352 or GPRA-MA). While it has not been established that all of these standards apply to the CFPB, they are instructive as examples of federal budgeting standards.


110

Finally, taking into consideration the early stage in the evolution of CFPB, we gathered information from budget formulation and execution officials at two relevant organizations: (1) the Office of the Comptroller of the Currency (OCC); and (2) the Federal Deposit Insurance Corporation (FDIC). We also contacted the Administrative Resource Center of the Bureau of the Public Debt to arrange a demonstration of their budget formulation and performance management solution. Our objective was to gather experiences, ideas, and recommendations from these agencies to offer to CFPB to further refine and improve its budgeting processes.




The bullets below describe specific provisions of the Dodd-Frank Act that establish requirements and/or evaluation criteria in the Budget area.

Sections 1017(a)(1) and (3) of the Dodd-Frank Act specify the process by which the bureau requests funding from the Board of Governors based on amounts determined by the Director to be reasonably necessary to carry out the authorities of the bureau.

Section 1017(a)(2) of the Dodd-Frank Act specifies the annual funding cap for the bureau

amounting to a fixed percentage of the total operating expenses of the Federal Reserve System. Further, this section specifies that the funds derived from the Federal Reserve System shall not be subject to review by the Committees on Appropriations of the House of Representatives and the Senate.

Section 1017(a)(4) of the Dodd-Frank Act requires CFPB to provide OMB with copies of the bureau’s financial operating plans and forecasts as well as copies of the quarterly reports of the financial condition and results of operations of the bureau. CFPB is required to prepare annual financial statements; implement and maintain financial management systems that comply substantially with Federal financial management systems requirements and applicable Federal accounting standards; and provide to the Comptroller General of the United States an assertion as to the effectiveness of the internal controls that apply to financial reporting by the bureau, using the standards established in section 3512(c) of title 31, United States Code. The CFPB financial statements shall not be consolidated with the financial statements of either the Board of Governors or the Federal Reserve System.

Section 1017(a)(5) of the Dodd-Frank Act specifies the Comptroller General shall annually audit the financial transactions of the bureau in accordance with the United States generally accepted government auditing standards and submit to the Congress a report of each annual


111

audit conducted under this subsection. A copy of each audit report shall also be furnished to the President and to the bureau at the time submitted to the Congress.

Section 1017(b) of the Dodd-Frank Act requires the Federal Reserve to establish a separate CFPB fund—maintained and established at a Federal Reserve bank—where all amounts transferred to the bureau shall be deposited.

Section 1017(e) of the Dodd-Frank Act authorizes the bureau Director to determine whether the funds set aside from the Federal Reserve System are sufficient to carry out the authorities of the bureau. If it is determined that the funds are insufficient, the Director shall prepare a report regarding the extent to which the funding needs are anticipated to exceed the funded amount. Based on this report, the bureau may request appropriations up to $200 million per year for fiscal years 2012 through 2014.


In order to assess achievement of organizational goals, we evaluated the progress that CFPB has made towards measurable goals that are documented in CFPB planning artifacts. The bullets below describe the specific organizational goals that are included in our analysis. In additional to our experiences with other comparable organizations, these goals were informed by our industry experiences, as well as case studies presented in GAO-03-669: Results-Oriented Cultures; Implementation Steps to Assist Mergers and Organizational Transformations (July 2003) and the Booz, Allen, Hamilton report to Treasury: Research & Analysis: Organizational Stand-ups Lessons Learned and Key Insights (May 2010).

Budget formulation and execution documentation reflects the overall organizational strategy.

Budget organization is set up to effectively meet the goals of CFPB.

Budget is formulated in a structured, comprehensive and useful manner.

Budget execution provides effective and timely communication to appropriate parties within CFPB management and the public.

Budget formulation and execution tools and reporting methods effectively support the needs of CFPB.


In order to assess achievement of performance standards and best practices, we evaluated the progress CFPB has made against two principal reference bases: (1) relevant OMB Circulars and Acts pertaining to budgeting, financial and performance management; and (2) other relevant U.S. federal agencies that have unique funding mechanisms and missions similar to that of CFPB.


112

Relevant OMB Circulars and Acts With respect to government wide budgeting, financial and performance management standards, we referenced OMB Circular A-11 Preparation, Submission, and Execution of the Budget; OMB Circular A-136, Financial Reporting Requirements; and OMB Circular A-123, Management’s Responsibility for Internal Control. We also referenced the Government Performance and Results Act (GPRA) Modernization Act of 2010 (Public Law 111-352 or GPRA-MA or the “Acts”).

OMB Circular A-11 maps out the basic budget policies that need to be followed and applicable laws, as well as the apportionment process and reporting requirements. Additionally, Circular A-11 provides a framework for strategic planning and performance monitoring.

OMB A-136 provides a reference for financial reporting guidance to Executive Branch departments, agencies, and entities required to submit audited financial statements, interim financial statements, and Performance and Accountability Reports.

OMB A-123 provides guidance to Federal managers on improving the accountability and effectiveness of Federal programs and operations by establishing, assessing, correcting, and reporting on internal control.

GPRA-MA creates a new government-wide planning and reporting framework and revises agency planning and reporting responsibilities. These guidelines include refined content requirements for strategic plans and priority goals, performance management plans, quarterly progress reviews, and performance reporting.

CFPB is currently working to clarify and document the applicability of these Circulars and Acts to CFPB operations. Meanwhile, the ASR team used these references as guiding principles and best practices sources for CFPB to use as its operations are stood up and established. The bullets below describe the specific performance standards that were included in our analysis.

Strategic Planning and Performance Management’s Relationship to Resource Allocation. We would expect evidence of progressive stages of strategic planning, as well as incorporation of GPRA-MA concepts that outline high-level organizational priorities, annual performance management plans, performance objectives and associated budget plans, progress reviews, accountability assignments, and plans for transparent monitoring and reporting.

Fund Control Administration. We would expect written policies that outline protocols for funding requests and transfers as well as procedural documentation related to internal control activities.

Budget Control / Execution and Reporting. We would expect documentation related to funds management that clearly identifies how the organization tracks commitments and obligations, along with identification of who within the organization is responsible for committing and obligating funds and levels of approval required. We would also expect


113

internal control procedural documentation related to budget control / execution and reporting activities.

Budgeting Processes for Relevant U.S. Federal Agencies

With respect to other relevant U.S. federal agencies with missions similar to CFPB’s and non-appropriated funding, we used outreach discussions with FDIC and OCC to gather information related to their current budget formulation processes and practices and how these might apply to CFPB. In addition, we contacted the Administrative Resource Center of the Bureau of the Public Debt to arrange a demonstration of the Budget Formulation & Execution Manager (BFEM) solution currently offered for budgeting and performance management automation. Our objective was to learn from the experiences, ideas, and recommendations of these agencies, so that CFPB might further define and improve its budgeting process.




Table 28 presents our assessment of the CFPB’s compliance with legal requirements. Each row in this table corresponds to a specific legal requirement. For each requirement, we describe the progress that the bureau has demonstrated to date, along with any recommendations for future action. As documented in Table 28, all relevant budgeting requirements under Title X of the Dodd-Frank Act have been addressed by the bureau and we offer no specific recommendations. Overall, we found that CFPB practices are documented and consistently performed. The bullets below summarize the demonstrated performance that emerged from our analysis.

CFPB funding requests and transfers are under the funding cap. Quarterly funding transfers have been prepared and presented to the Federal Reserve. CFPB funding for FY 2010 and 2011 was approximately 3.6% of the 2009 operating budget of the Federal Reserve System. The initial FY 2012 budget submitted to OMB (and included in the President’s Budget) was approximately 6.6% of the 2009 operating budget of the Federal Reserve System. In all cases, these funding requests are substantially below the funding caps defined by Dodd-Frank Section 1017(a)(2).

CFPB has no plans for appropriations requests. CFPB funding through the Federal Reserve is not subject to the traditional formulation and review of the Congressional appropriations process. However, should the bureau Director determine a need for appropriated funds, he/she may prepare a report that illustrates how funding needs exceed those dollars that are set aside from the Federal Reserve System as specified under Dodd-Frank Section 1017(e). Such appropriations cannot exceed $200 million per year for the fiscal years 2010 through 2014. CFPB did not request an appropriation in either FY 2011 or 2012.


114

CFPB has met the requirements to provide financial results to OMB. CFPB has provided copies of its financial operating plans as well as budget execution reports to OMB. CFPB plans to provide its annual financial statements to OMB on or about November 15.

CFPB’s internal controls testing and the GAO financial audit are underway. CFPB has hired an Internal Control over Financial Reporting (ICFR) contractor to perform a risk assessment, develop test plans, and provide CFPB management with test results. CFPB plans to provide an Assertion of Internal Controls for FY 2011. Further, as required under Dodd-Frank Section 1017(a)(5), an engagement letter has been executed with GAO to conduct an independent financial statement audit for CFPB for FY 2011.

CFPB leverages the BPD Administrative Resource Center for financial management processing. CFPB financial management systems are centrally hosted by the BPD Administrative Resource Center, which meets the requirements under Dodd-Frank Section 1017(a)(4)(C).


Table 29 presents our assessment of the CFPB’s achievement of organizational goals. Each row in this table corresponds to a specific organizational goal. For each goal, we describe the expected progress we believe CFPB should have made during the bureau’s stand-up implementation and since the transfer date, the progress that the bureau has demonstrated to date, along with recommendations for future action. The bullets below highlight our key findings and recommendations

CFPB should complete policy and procedural documentation. CFPB should continue its work underway to more-fully document policies related to critical aspects of the Federal Reserve funding request and transfer process. In addition, CFPB should continue to more-fully document policies related to budget formulation and execution / commitment control. Supplemental documentation should be developed to define detailed funding and budgetary procedures, roles and responsibilities, and performance management and monitoring practices.

CFPB should build a staffing plan for the budget organization. CFPB has been hiring additional budget staff over the past several months. As the bureau continues to expand its operations, we encourage the bureau to continue to reach out to other comparable U.S. federal agencies with unique funding mechanisms and missions similar to that of CFPB (e.g., FDIC and OCC) to garner ideas and recommendations for the structure and staffing levels of the budgeting operations.

CFPB should continue to expand transparency of funding and expenditures. As the CFPB grows, we expect the bureau will continue to expand the amount of information available to the public (e.g., operational plans, funding levels, expenditures, financial performance management against bureau priorities, and the like).

CFPB should increase automation of budget formulation and performance management. As is expected, much of CFPB’s budget formulation process is manual and leverages spreadsheets – some of which are quite large and complex. CFPB should continue comparative analysis with other similar agencies to evaluate options for enhanced budget


115

formulation and performance management automation. Where possible, we recommend leveraging pre-existing solutions to best serve the bureau at this stage of its evolution versus developing a bureau-specific solution.


Table 30 presents our assessment of the CFPB’s alignment with performance standards and best practices adapted from respective components of OMB Circulars A-11, A-136 and A-123 as well as GPRA-MA. For each aspect of performance, we provide the following information: (1) a rating of CFPB’s performance to date, using a stoplight scale (i.e., Red, Yellow or Green); (2) a summary of demonstrated performance; (3) the priority of future progress in this area, based on the importance of the performance area for a start-up organization; and (4) recommendations for future action. The bullets below highlight our key findings and recommendations.

CFPB should continue to clarify and document the applicability of budget-related Circulars and Acts. CFPB continues its efforts to clarify and document the applicability to CFPB operations of various budgeting and performance management Circulars and Acts. CFPB has already adopted and will continue to integrate into its operations the principles and concepts contained within the relevant Circulars and Acts and the bureau will implement, where possible, best practice components. We support the bureau’s plans to both document and implement all applicable standards and best practices.

CFPB should incorporate “outcome” objectives in strategic planning. We understand that bureau-wide strategic plans are under development within CFPB. While this performance audit did not evaluate the progress nor content of the current draft plans, we encourage CFPB’s progressive stages of strategic planning to incorporate GPRA-MA concepts outlining high-level organizational priorities, “outcome” objectives, annual performance management plans, relationship to funding and budgetary plans, progress review plans, accountability assignments, and plans for transparent monitoring and reporting.

CFPB should load its budget at a divisional level. Starting with the FY 2013 President’s Budget (currently being formulated) and the FY 2012 Operations Plan for CFPB, the bureau plans to construct its budget on a bottom-up basis by cost center. For the FY 2012 Operations Plan, CFPB plans to load its budget in its financial management system on a divisional basis for enhanced execution and control. We support the bureau’s plan to begin loading the budget at a divisional level in FY 2012 for more effective management, control and accountability.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

116

Tab

le 2

8: C

omp

lian

ce w

ith

Leg

al R

equ

irem

ents

Lega

l Req

uire

men

t De

mon

stra

ted

Perfo

rman

ce

Find

ing

/ Rec

omm

enda

tion

SEC.

101

7. F

UNDI

NG; P

ENAL

TIES

AND

FIN

ES.

(a) T

RANS

FER

OF

FUND

S FR

OM

BO

ARD

OF

GO

VERN

ORS

.—

(1) I

N G

ENER

AL.—

Each

year

(or q

uarte

r of s

uch

year

), be

ginn

ing o

n th

e de

signa

ted

trans

fer d

ate,

and

eac

h qu

arte

r th

erea

fter,

the

Boar

d of

Gov

erno

rs s

hall t

rans

fer t

o th

e Bu

reau

from

the

com

bine

d ea

rnin

gs o

f the

Fed

eral

Res

erve

Sys

tem

, the

am

ount

det

erm

ined

by t

he D

irect

or to

be

reas

onab

ly ne

cess

ary

to ca

rry o

ut th

e au

thor

ities o

f the

Bur

eau

unde

r Fed

eral

cons

umer

fin

ancia

l law,

takin

g in

to a

ccou

nt s

uch

othe

r sum

s m

ade

avai

labl

e to

the

Bure

au fr

om th

e pr

eced

ing ye

ar (o

r qua

rter o

f suc

h ye

ar).

• Do

cum

ente

d bu

dget

fund

ing

proc

ess.

• Fe

dera

l Res

erve

acc

ount

ser

vices

ag

reem

ent.

• Fo

rmal

app

rove

d tra

nsfe

r req

uest

s.

• Fu

ndin

g tra

nsfe

rs b

egan

08/

10/2

010.

CFPB

pla

ns a

re d

ocum

ente

d an

d pr

oces

ses

are

cons

isten

tly

perfo

rmed

.

(2) F

UNDI

NG C

AP.—

(A) I

N G

ENER

AL.—

Notw

ithst

andi

ng p

arag

raph

(1),

and

in a

ccor

danc

e wi

th th

is pa

ragr

aph,

the

amou

nt th

at s

hall b

e tra

nsfe

rred

to

the

Bure

au in

eac

h fis

cal y

ear s

hall n

ot e

xcee

d a

fixed

per

cent

age

of th

e to

tal o

pera

ting

expe

nses

of t

he F

eder

al R

eser

ve S

yste

m,

as re

porte

d in

the

Annu

al R

epor

t, 20

09, o

f the

Boa

rd o

f Gov

erno

rs, e

qual

to—

(i) 1

0 pe

rcen

t of s

uch

expe

nses

in fis

cal y

ear 2

011;

(ii) 1

1 pe

rcen

t of s

uch

expe

nses

in fis

cal y

ear 2

012;

and

(iii) 1

2 pe

rcen

t of s

uch

expe

nses

in fis

cal y

ear 2

013,

and

in e

ach

year

ther

eafte

r.

(B) A

DJUS

TMEN

T O

F AM

OUN

T.—

The

dolla

r am

ount

refe

rred

to in

subp

arag

raph

(A)(i

ii) sh

all b

e ad

juste

d H.

R. 4

173—

601

annu

ally,

usin

g th

e pe

rcen

t incr

ease

, if a

ny, in

the

empl

oym

ent c

ost in

dex

for t

otal

com

pens

atio

n fo

r Sta

te a

nd lo

cal g

over

nmen

t wo

rker

s pub

lishe

d by

the

Fede

ral G

over

nmen

t, or

the

succ

esso

r ind

ex th

eret

o, fo

r the

12-

mon

th p

erio

d en

ding

on

Sept

embe

r 30

of th

e ye

ar p

rece

ding

the

trans

fer.

(C) R

EVIE

WAB

ILIT

Y.—

Notw

ithst

andi

ng a

ny o

ther

pro

vision

in th

is titl

e, th

e fu

nds

deriv

ed fr

om th

e Fe

dera

l Res

erve

Sys

tem

pu

rsua

nt to

this

subs

ectio

n sh

all n

ot b

e su

bject

to re

view

by th

e Co

mm

ittees

on

Appr

opria

tions

of t

he H

ouse

of R

epre

sent

ative

s an

d th

e Se

nate

.

• Pe

r CFP

B, a

ctua

l fund

ing

prov

ided

for F

Y 20

10 a

nd 2

011

has

reac

hed

appr

oxim

atel

y 3.

6% o

f the

Fed

eral

Re

serv

e’s

2009

ope

ratin

g bu

dget

.

• CF

PB's

initia

l FY

2012

bud

get s

ubm

itted

to O

MB

(and

inclu

ded

in th

e Pr

esid

ent's

Bu

dget

) is

appr

oxim

atel

y 6.

6% o

f the

Fe

dera

l Res

erve

's 20

09 o

pera

ting

budg

et.

CFPB

pla

ns a

re d

ocum

ente

d an

d pr

oces

ses

are

cons

isten

tly

perfo

rmed

.

(3) T

RANS

ITIO

N PE

RIO

D.—

Begi

nning

on

the

date

of e

nactm

ent o

f thi

s Ac

t and

unt

il the

des

igna

ted

trans

fer d

ate,

the

Boar

d of

Gov

erno

rs s

hall t

rans

fer t

o th

e Bu

reau

the

amou

nt e

stim

ated

by

the

Secr

etar

y ne

eded

to ca

rry o

ut th

e au

thor

ities

gran

ted

to th

e Bu

reau

und

er F

eder

al co

nsum

er fin

ancia

l law,

from

the

date

of e

nact

men

t of t

his

Act u

ntil t

he d

esig

nate

d tra

nsfe

r dat

e.

• Do

cum

ente

d bu

dget

fund

ing

proc

ess.

• Fo

rmal

app

rove

d tra

nsfe

r req

uest

s.

• Bu

dget

exe

cutio

n tra

ckin

g an

d st

atus

re

porti

ng.

CFPB

pla

ns a

re d

ocum

ente

d an

d pr

oces

ses

are

cons

isten

tly

perfo

rmed

.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

117

Lega

l Req

uire

men

t De

mon

stra

ted

Perfo

rman

ce

Find

ing

/ Rec

omm

enda

tion

(4) B

UDG

ET A

ND F

INAN

CIAL

MAN

AGEM

ENT.

—

(A) F

INAN

CIAL

OPE

RATI

NG P

LANS

AND

FO

RECA

STS.

—Th

e Di

rect

or s

hall p

rovid

e to

the

Dire

ctor

of t

he O

ffice

of

Man

agem

ent a

nd B

udge

t cop

ies o

f the

finan

cial o

pera

ting

plan

s an

d fo

reca

sts

of th

e Di

rect

or, a

s pr

epar

ed b

y th

e Di

rect

or in

the

ordi

nary

cour

se o

f the

ope

ratio

ns o

f the

Bur

eau,

and

copie

s of

the

quar

terly

repo

rts o

f the

finan

cial c

ondi

tion

and

resu

lts o

f op

erat

ions

of t

he B

urea

u, a

s pr

epar

ed b

y th

e Di

rect

or in

the

ordi

nary

cou

rse

of th

e op

erat

ions

of th

e Bu

reau

.

(B) F

INAN

CIAL

STA

TEM

ENTS

.—Th

e Bu

reau

sha

ll pre

pare

ann

ually

a s

tate

men

t of—

(i) a

sset

s an

d lia

biliti

es a

nd s

urpl

us o

r def

icit;

(ii) in

com

e an

d ex

pens

es; a

nd

(iii) s

ourc

es a

nd a

pplic

atio

n of

fund

s.

(C) F

INAN

CIAL

MAN

AGEM

ENT

SYST

EMS.

— T

he B

urea

u sh

all im

plem

ent a

nd m

aint

ain

finan

cial m

anag

emen

t sys

tem

s th

at

com

ply s

ubst

antia

lly w

ith F

eder

al fin

ancia

l man

agem

ent s

yste

ms

requ

irem

ents

and

app

licab

le F

eder

al a

ccou

ntin

g st

anda

rds.

(D) A

SSER

TIO

N O

F IN

TERN

AL C

ONT

ROLS

.— T

he D

irect

or sh

all p

rovid

e to

the

Com

ptro

ller G

ener

al o

f the

Uni

ted

Stat

es a

n as

serti

on a

s to

the

effe

ctive

ness

of t

he in

tern

al c

ontro

ls th

at a

pply

to fin

ancia

l rep

ortin

g by

the

Bure

au, u

sing

the

stand

ards

es

tabl

ished

in s

ectio

n 35

12(c

) of t

itle 3

1, U

nite

d St

ates

Cod

e.

(E) R

ULE

OF

CONS

TRUC

TIO

N.—

This

subs

ectio

n m

ay n

ot b

e co

nstru

ed a

s im

plyin

g an

y ob

ligat

ion

on th

e pa

rt of

the

Dire

ctor

to

cons

ult w

ith o

r obt

ain

the

cons

ent o

r app

rova

l of t

he D

irect

or o

f the

Offic

e of

Man

agem

ent a

nd B

udge

t with

resp

ect t

o an

y re

port,

pl

an, f

orec

ast,

or o

ther

info

rmat

ion

refe

rred

to in

sub

para

grap

h (A

) or a

ny ju

risdic

tion

or o

vers

ight

ove

r the

affa

irs o

r ope

ratio

ns o

f th

e Bu

reau

.

(F) F

INAN

CIAL

STA

TEM

ENTS

.—Th

e fin

ancia

l sta

tem

ents

of t

he B

urea

u sh

all n

ot b

e co

nsol

idat

ed w

ith th

e fin

ancia

l sta

tem

ents

of e

ither

the

Boar

d of

Gov

erno

rs o

r the

Fed

eral

Res

erve

Sys

tem

.

• Co

pies

of f

inan

cial o

pera

ting

plan

s pr

ovid

ed to

OM

B.

• Co

pies

of b

udge

t exe

cutio

n re

ports

pr

ovid

ed to

OM

B.

• An

nual

finan

cial s

tate

men

ts p

lann

ed to

be

sha

red

with

OM

B on

or a

bout

No

vem

ber 1

5.

• Th

e CF

PB fin

ancia

l sta

tem

ents

hav

e ne

ver b

een

cons

olid

ated

with

eith

er th

e De

partm

ent o

f the

Tre

asur

y, th

e Bo

ard

of

Gov

erno

rs o

f the

Fed

eral

, or t

he F

eder

al

Rese

rve

Syst

em.

• Im

plem

ente

d Fi

nanc

ial M

anag

emen

t sy

stem

sui

te h

oste

d by

Tre

asur

y BP

D –

Adm

inist

rativ

e Re

sour

ce C

ente

r.

• CF

PB h

ired

an In

tern

al C

ontro

l Ove

r Fi

nanc

ial R

epor

ting

(ICFR

) con

tract

or to

pe

rform

a ri

sk a

sses

smen

t, de

velo

p te

st

plan

s, a

nd p

rovid

e CF

PB m

anag

emen

t wi

th te

st re

sults

.

• CF

PB p

lans

to p

rovid

e an

Ass

ertio

n of

In

tern

al C

ontro

ls fo

r FY

2011

.

CFPB

pla

ns a

re d

ocum

ente

d an

d pr

oces

ses

are

cons

isten

tly

perfo

rmed

.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

118

Lega

l Req

uire

men

t De

mon

stra

ted

Perfo

rman

ce

Find

ing

/ Rec

omm

enda

tion

(5) A

UDIT

OF

THE

BURE

AU.—

H. R

. 417

3—60

2

(A) I

N G

ENER

AL.—

The

Com

ptro

ller G

ener

al s

hall a

nnua

lly a

udit t

he fin

ancia

l tran

sact

ions

of t

he B

urea

u in

acc

orda

nce

with

the

Unite

d St

ates

gen

eral

ly ac

cept

ed g

over

nmen

t aud

iting

stan

dard

s, a

s m

ay b

e pr

escr

ibed

by

the

Com

ptro

ller G

ener

al o

f the

Uni

ted

Stat

es. T

he a

udit s

hall b

e co

nduc

ted

at th

e pla

ce o

r pla

ces

wher

e ac

coun

ts o

f the

Bur

eau

are

norm

ally

kept

. The

repr

esen

tativ

es

of th

e G

over

nmen

t Acc

ount

abilit

y O

ffice

shal

l hav

e ac

cess

to th

e pe

rson

nel a

nd to

all b

ooks

, acc

ount

s, d

ocum

ents

, pap

ers,

re

cord

s (in

cludin

g el

ectro

nic

reco

rds)

, rep

orts

, file

s, a

nd a

ll oth

er p

aper

s, a

utom

ated

dat

a, th

ings

, or p

rope

rty b

elon

ging

to o

r und

er

the

cont

rol o

f or u

sed

or e

mpl

oyed

by

the

Bure

au p

erta

inin

g to

its fin

ancia

l tran

sacti

ons

and

nece

ssar

y to

facil

itate

the

audi

t, an

d su

ch re

pres

enta

tives

shal

l be

affo

rded

full f

acilit

ies

for v

erify

ing

trans

actio

ns w

ith th

e ba

lance

s or

sec

uritie

s he

ld b

y dep

osito

ries,

fis

cal a

gent

s, a

nd cu

stodi

ans.

All s

uch

book

s, a

ccou

nts,

doc

umen

ts, re

cord

s, re

ports

, file

s, p

aper

s, a

nd p

rope

rty o

f the

Bur

eau

shal

l rem

ain in

pos

sess

ion

and

cust

ody

of th

e Bu

reau

. The

Com

ptro

ller G

ener

al m

ay o

btain

and

dup

licat

e an

y su

ch b

ooks

, ac

coun

ts, d

ocum

ents

, rec

ords

, wor

king

pape

rs, a

utom

ated

dat

a an

d file

s, o

r oth

er in

form

atio

n re

leva

nt to

suc

h au

dit w

ithou

t cos

t to

the

Com

ptro

ller G

ener

al, a

nd th

e rig

ht o

f acc

ess

of th

e Co

mpt

rolle

r Gen

eral

to s

uch

info

rmat

ion

shal

l be

enfo

rcea

ble

purs

uant

to

sec

tion

716(

c) o

f title

31,

Uni

ted

Stat

es C

ode.

(B) R

EPO

RT.—

The

Com

ptro

ller G

ener

al s

hall s

ubm

it to

the

Cong

ress

a re

port

of e

ach

annu

al a

udit c

ondu

cted

und

er th

is su

bsec

tion.

The

repo

rt to

the

Cong

ress

sha

ll set

forth

the

scop

e of

the

audi

t and

sha

ll inc

lude

the

stat

emen

t of a

sset

s an

d lia

biliti

es

and

surp

lus

or d

efici

t, th

e st

atem

ent o

f inco

me

and

expe

nses

, the

sta

tem

ent o

f sou

rces

and

app

licat

ion

of fu

nds,

and

such

co

mm

ents

and

info

rmat

ion

as m

ay b

e de

emed

nec

essa

ry to

info

rm C

ongr

ess

of th

e fin

ancia

l ope

ratio

ns a

nd co

nditio

n of

the

Bure

au, t

oget

her w

ith su

ch re

com

men

datio

ns w

ith re

spec

t the

reto

as

the

Com

ptro

ller G

ener

al m

ay d

eem

adv

isabl

e. A

cop

y of

ea

ch re

port

shal

l be

furn

ished

to th

e Pr

esid

ent a

nd to

the

Bure

au a

t the

time

subm

itted

to th

e Co

ngre

ss.

(C) A

SSIS

TANC

E AN

D CO

STS.

—Fo

r the

pur

pose

of c

ondu

ctin

g an

aud

it und

er th

is su

bsec

tion,

the

Com

ptro

ller G

ener

al m

ay, in

th

e di

scre

tion

of th

e Co

mpt

rolle

r Gen

eral

, em

ploy

by

cont

ract

, with

out r

egar

d to

sect

ion

3709

of t

he R

evise

d St

atut

es o

f the

Uni

ted

Stat

es (4

1 U.

S.C.

5),

prof

essio

nal s

ervic

es o

f firm

s an

d or

gani

zatio

ns o

f cer

tified

pub

lic a

ccou

ntan

ts fo

r tem

pora

ry p

erio

ds o

r for

sp

ecia

l pur

pose

s. U

pon

the

requ

est o

f the

Com

ptro

ller G

ener

al, t

he D

irect

or o

f the

Bur

eau

shal

l tran

sfer t

o th

e G

over

nmen

t Ac

coun

tabi

lity O

ffice

from

fund

s av

aila

ble,

the

amou

nt re

ques

ted

by th

e Co

mpt

rolle

r Gen

eral

to c

over

the

full c

osts

of a

ny a

udit

and

repo

rt co

nduc

ted

by th

e Co

mpt

rolle

r Gen

eral

. The

Com

ptro

ller G

ener

al sh

all c

redi

t fun

ds tr

ansf

erre

d to

the

acco

unt

esta

blish

ed fo

r sal

arie

s and

exp

ense

s of

the

Gov

ernm

ent A

ccou

ntab

ility

Offic

e, a

nd s

uch

amou

nt s

hall b

e av

ailab

le u

pon

rece

ipt

and

with

out f

iscal

year

limita

tion

to c

over

the

full c

osts

of t

he a

udit a

nd re

port.

• An

eng

agem

ent le

tter h

as b

een

exec

uted

wi

th th

e G

AO to

con

duct

an

inde

pend

ent

finan

cial s

tate

men

t aud

it for

CFP

B fo

r FY

2011

.

• Th

e sc

ope

of th

e G

AO e

ngag

emen

t lette

r ad

dres

ses

the

requ

irem

ents

of t

he

legi

slatio

n.

CFPB

pla

ns a

re d

ocum

ente

d an

d pr

oces

ses

are

cons

isten

tly

perfo

rmed

.

(b) C

ONS

UMER

FIN

ANCI

AL P

ROTE

CTIO

N FU

ND.—

H. R

. 417

3—60

3

(1) S

EPAR

ATE

FUND

IN F

EDER

AL R

ESER

VE E

STAB

LISH

ED.—

Ther

e is

esta

blish

ed in

the

Fede

ral R

eser

ve a

sep

arat

e fu

nd, t

o be

know

n as

the

‘‘Bur

eau

of C

onsu

mer

Fin

ancia

l Pro

tect

ion

Fund

’’ (re

ferre

d to

in th

is se

ctio

n as

the

‘‘Bur

eau

Fund

’’). T

he B

urea

u Fu

nd sh

all b

e m

aint

aine

d an

d es

tabl

ished

at a

Fed

eral

rese

rve

bank

, in a

ccor

danc

e wi

th s

uch

requ

irem

ents

as

the

Boar

d of

Gov

erno

rs m

ay im

pose

.

(2) F

UND

RECE

IPTS

.—Al

l am

ount

s tra

nsfe

rred

to th

e Bu

reau

und

er s

ubse

ctio

n (a

) sha

ll be

depo

sited

into

the

Bure

au F

und.

• Do

cum

ente

d bu

dget

fund

ing

proc

ess.

• Fe

dera

l Res

erve

acc

ount

ser

vices

ag

reem

ent.

• A

sepa

rate

fund

has

bee

n es

tabl

ished

at

the

Fede

ral R

eser

ve fo

r CFP

B an

d al

l am

ount

s tra

nsfe

rred

by th

e Fe

dera

l Re

serv

e ha

ve b

een

depo

sited

into

the

sepa

rate

CFP

B fu

nd.

CFPB

pla

ns a

re d

ocum

ente

d an

d pr

oces

ses

are

cons

isten

tly

perfo

rmed

.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

119

Lega

l Req

uire

men

t De

mon

stra

ted

Perfo

rman

ce

Find

ing

/ Rec

omm

enda

tion

(e) A

UTHO

RIZA

TIO

N O

F AP

PRO

PRIA

TIO

NS; A

NNUA

L RE

PORT

.—

(1) D

ETER

MIN

ATIO

N RE

GAR

DING

NEE

D FO

R AP

PRO

PRIA

TED

FUND

S.—

(A)

IN G

ENER

AL.—

The

Dire

ctor

is a

utho

rized

to d

eter

min

e th

at s

ums

avai

lable

to th

e Bu

reau

und

er th

is se

ctio

n wi

ll no

t be

suffic

ient

to ca

rry o

ut th

e au

thor

ities

of th

e Bu

reau

und

er F

eder

al co

nsum

er fin

ancia

l law

for t

he u

pcom

ing

year

.

(B) R

EPO

RT R

EQUI

RED.

—W

hen

mak

ing

a de

term

inat

ion

unde

r sub

para

grap

h (A

), th

e Di

rect

or s

hall p

repa

re a

repo

rt re

gard

ing

the

fund

ing

of th

e Bu

reau

, inc

ludin

g th

e as

sets

and

liab

ilitie

s of

the

Bure

au, a

nd th

e ex

tent

to w

hich

the

fund

ing

need

s of

the

Bure

au a

re a

ntici

pate

d to

exc

eed

the

leve

l of t

he a

mou

nt s

et fo

rth in

sub

sect

ion

(a)(2

). Th

e Di

rect

or s

hall s

ubm

it th

e re

port

to th

e Pr

esid

ent

and

to t

he C

omm

ittee

on A

ppro

pria

tions

of

the

Sena

te a

nd t

he C

omm

ittee

on A

ppro

pria

tions

of

the

Hous

e of

Re

pres

enta

tives

.

(2)

AUTH

ORI

ZATI

ON

OF

APPR

OPR

IATI

ONS

.—If

the

Dire

ctor

mak

es th

e de

term

inat

ion

and

subm

its th

e re

port

purs

uant

to

para

grap

h (1

), th

ere

are

here

by a

utho

rized

to b

e ap

prop

riate

d to

the

Bure

au, f

or th

e pu

rpos

es o

f car

ryin

g ou

t the

aut

horit

ies

gran

ted

in F

eder

al c

onsu

mer

finan

cial la

w, $

200,

000,

000

for e

ach

of fis

cal y

ears

201

0, 2

011,

201

2, 2

013,

and

201

4.

(3)

APPO

RTIO

NMEN

T.—

Notw

ithst

andi

ng a

ny o

ther

pro

visio

n of

law

, th

e am

ount

s in

par

agra

ph (

2) s

hall

be s

ubje

ct t

o ap

porti

onm

ent u

nder

sec

tion

1517

of t

itle 3

1, U

nite

d St

ates

Cod

e, a

nd re

stric

tions

that

gen

eral

ly ap

ply to

the

use

of a

ppro

pria

ted

fund

s in

title

31,

Uni

ted

Stat

es C

ode,

and

oth

er la

ws.

(4) A

NNUA

L RE

PORT

.—Th

e Di

rect

or s

hall p

repa

re a

nd s

ubm

it a re

port,

on

an a

nnua

l bas

is, to

the

Com

mitte

e on

App

ropr

iatio

ns

of th

e Se

nate

and

the

Com

mitte

e on

App

ropr

iatio

ns o

f the

Hou

se o

f Rep

rese

ntat

ives

rega

rdin

g th

e fin

ancia

l ope

ratin

g pla

ns a

nd

fore

cast

s of

the

Dire

ctor,

the

finan

cial c

ondi

tion

and

resu

lts o

f ope

ratio

ns o

f the

Bur

eau,

and

the

sour

ces

and

appl

icatio

n of

fund

s of

the

Bure

au, in

cludin

g an

y fu

nds a

ppro

pria

ted

in a

ccor

danc

e wi

th th

is su

bsec

tion.

• CF

PB is

not

pla

nnin

g to

requ

est a

n ap

prop

riatio

n in

eith

er F

Y 20

11 o

r 201

2.

CFPB

pla

ns a

re d

ocum

ente

d an

d pr

oces

ses

are

cons

isten

tly

perfo

rmed

.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

120

Tab

le 2

9: A

chie

vem

ent

of O

rgan

izat

ion

al G

oals

Org

aniz

atio

nal G

oal

Expe

cted

Per

form

ance

De

mon

stra

ted

Perfo

rman

ce

Find

ing

/ Rec

omm

enda

tion

Budg

et fo

rmul

atio

n an

d ex

ecut

ion

docu

men

tatio

n re

flect

s th

e ov

eral

l or

gani

zatio

nal s

trate

gy

• O

rgan

izatio

nal s

trate

gies

and

“out

com

e”

obje

ctive

s pr

ovid

e di

rect

line-

of-s

ight

for

budg

et fo

rmul

atio

n an

d ex

ecut

ion

repo

rting

. •

Incr

ease

d as

socia

tion

of “o

utco

mes

” wi

th re

late

d sp

end.

• CF

PB is

in th

e pr

oces

s of

pre

parin

g a

stra

tegi

c pl

an.

• CF

PB h

as n

ot y

et b

egun

ass

ocia

ting

reso

urce

s wi

th “o

utco

mes

” or

perfo

rman

ce m

etric

s.

Refe

r to

com

men

ts in

Tab

le 3

0 un

der “

Stra

tegi

c Pl

anni

ng a

nd P

erfo

rman

ce M

anag

emen

t’s

Rela

tions

hip

to R

esou

rce

Allo

catio

ns.”

Budg

et o

rgan

izatio

n is

set u

p to

effe

ctive

ly m

eet t

he g

oals

of C

FPB

• Dr

aft o

rgan

izatio

nal a

nd s

taffin

g pl

an

unde

r rev

iew

for f

inal

app

rova

l. •

Draf

t hirin

g pl

ans

in p

lace

. •

Draf

t bud

get p

ositio

n de

scrip

tions

.

• Th

e bu

dget

offic

e re

ports

into

the

offic

e of

the

CFO

.

• Cu

rrent

ly th

ere

are

3 po

sitio

ns in

the

Budg

et O

ffice.

Eac

h of

thes

e in

divid

uals

brin

g sig

nific

ant b

udge

t exp

erie

nce

to

CFPB

.

• Po

tent

ial to

add

bud

get s

taff

in k

ey

depa

rtmen

ts, if

it is

deem

ed n

eces

sary

.

As th

e bu

reau

con

tinue

s to

exp

and

its

oper

atio

ns, w

e en

cour

age

the

bure

au to

co

ntin

ue to

reac

h ou

t to

othe

r com

para

ble

U.S.

fe

dera

l age

ncie

s wi

th u

niqu

e fu

ndin

g m

echa

nism

s an

d m

issio

ns s

imila

r to

that

of

CFPB

(e.g

., FD

IC a

nd O

CC) t

o ga

rner

idea

s an

d re

com

men

datio

ns fo

r the

stru

ctur

e an

d st

affin

g le

vels

of th

e bu

dget

ing

oper

atio

ns.

Budg

et is

form

ulat

ed in

a s

truct

ured

, co

mpr

ehen

sive

and

usef

ul m

anne

r

• Bu

dget

pol

icies

dra

fted

and

unde

r re

view

for a

ppro

val.

• Bu

dget

pro

cess

es fo

r for

mul

atio

n do

cum

ente

d an

d in

pla

ce.

• O

rgan

izatio

nal c

omm

unica

tion

has

been

pr

ovid

ed to

bot

h al

ert a

nd in

stru

ct

parti

cipan

ts in

the

budg

et fo

rmul

atio

n pr

oces

s.

• An

ann

ual O

pera

ting

Plan

is u

sed

to

synt

hesiz

e th

e bu

dget

form

ulat

ion

effo

rts.

• Be

nchm

arks

and

fore

cast

s ha

ve b

een

used

to b

uild

the

star

t-up

budg

ets

(esp

ecia

lly in

the

area

of w

orkf

orce

pl

anni

ng).

• Th

e fo

rmul

atio

n is

pres

ente

d to

ex

ecut

ive m

anag

emen

t for

revie

w,

revis

ion,

and

app

rova

l.

Refe

r to

com

men

ts in

Tab

le 3

0 un

der “

Budg

et

Cont

rol /

Exec

utio

n an

d Re

porti

ng.”

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

121

Org

aniz

atio

nal G

oal

Expe

cted

Per

form

ance

De

mon

stra

ted

Perfo

rman

ce

Find

ing

/ Rec

omm

enda

tion

Budg

et e

xecu

tion

prov

ides

effe

ctive

and

tim

ely

com

mun

icatio

n to

app

ropr

iate

pa

rties

with

in C

FPB

man

agem

ent a

nd th

e pu

blic

• Bu

dget

pro

cess

es fo

r exe

cutio

n an

d co

mm

itmen

t con

trol d

ocum

ente

d an

d in

pl

ace.

•

Inte

rnal

con

trols

docu

men

tatio

n dr

afte

d an

d un

der r

evie

w fo

r app

rova

l. •

Mon

thly

and

quar

terly

bud

get e

xecu

tion

repo

rting

per

form

ed.

• Bu

dget

exe

cutio

n re

sults

repo

rted

and

publ

ished

on

exte

rnal

web

sites

to

prom

ote

trans

pare

ncy.

• CF

PB h

as p

oste

d in

form

atio

n re

gard

ing

finan

cial in

form

atio

n on

line.

• D

ocum

ents

ava

ilabl

e in

clude

:

• CF

O u

pdat

es th

at s

umm

arize

sp

endi

ng to

dat

e;

• Bu

dget

in b

rief d

ocum

ents

;

• CF

PB b

udge

t for

FY

2011

su

bmitte

d to

OM

B

• Bu

dget

con

trol is

bei

ng m

onito

red

thro

ugh

bi-w

eekly

bud

get t

o ac

tual

re

ports

from

the

acco

untin

g sy

stem

.

• IC

FR ri

sk a

sses

smen

t and

con

trols

test

ing

has

begu

n le

vera

ging

con

tract

or

reso

urce

s.

CFPB

has

mad

e go

od p

rogr

ess

with

rega

rd to

tra

nspa

renc

y an

d co

mm

unica

tion,

bot

h in

tern

ally

as w

ell a

s ex

tern

ally.

As

thei

r bud

get

deta

il pro

gres

ses,

we

expe

ct th

at th

ey w

ill co

ntin

ue to

exp

and

the

amou

nt o

f info

rmat

ion

avai

labl

e to

the

publ

ic (e

.g.,

oper

atio

nal p

lans

, fu

ndin

g le

vels,

exp

endi

ture

s, p

erfo

rman

ce

man

agem

ent a

gain

st b

urea

u pr

iorit

ies)

.

Budg

et fo

rmul

atio

n an

d ex

ecut

ion

tool

s an

d re

porti

ng m

etho

ds e

ffect

ively

supp

ort t

he

need

s of

CFP

B

• Au

tom

ated

tool

s us

ed to

form

ulat

e th

e bu

dget

as

well a

s to

per

form

bud

get

exec

utio

n an

d co

mm

itmen

t con

trol.

• Dr

aft lo

ng-ra

nge

plan

s in

pla

ce fo

r co

mpr

ehen

sive

budg

et fo

rmul

atio

n an

d G

PRA-

MA

tool

(s).

• Bu

dget

form

ulat

ion

is pr

imar

ily d

one

on

spre

adsh

eets

.

• T

he b

urea

u lo

ads

the

budg

et a

t the

CF

PB le

vel c

urre

ntly,

but

pla

ns a

di

visio

nal le

vel lo

ad fo

r FY

2012

.

• C

FPB

uses

the

BPD

Fina

ncia

l M

anag

emen

t sys

tem

for b

udge

t ex

ecut

ion

and

com

mitm

ent c

ontro

l.

Muc

h of

this

proc

ess

is m

anua

l or l

ever

agin

g sp

read

shee

ts, w

hich

is e

xpec

ted.

CFP

B sh

ould

co

ntin

ue c

ompa

rativ

e an

alys

is wi

th o

ther

sim

ilar

agen

cies

to e

valu

ate

optio

ns fo

r enh

ance

d bu

dget

form

ulat

ion

and

perfo

rman

ce

man

agem

ent a

utom

atio

n.

Inde

pend

ent P

erfo

rman

ce A

udit

of C

FPB

Ope

ratio

ns a

nd B

udge

t O

ctob

er 1

5, 2

011

122

Tab

le 3

0: A

lign

men

t w

ith

Per

form

ance

Sta

nd

ard

s

Fact

or

Scor

e Su

mm

ary

of P

erfo

rman

ce

Prio

rity

Find

ing

/ Rec

omm

enda

tion

Stra

tegi

c Pl

anni

ng

and

Perfo

rman

ce

Man

agem

ent’s

Re

latio

nshi

p to

Re

sour

ce A

lloca

tions

CF

PB p

rovid

ed c

ompo

nent

-leve

l, dep

artm

enta

l pla

ns d

evel

oped

as

part

of th

e st

and-

up im

plem

enta

tion

activ

ities

and

also

use

d to

su

ppor

t the

FY

2012

Ope

ratio

ns P

lan

form

ulat

ion

CF

PB p

rovid

ed c

omm

unica

tions

and

pla

nnin

g do

cum

enta

tion

rela

ted

to its

cur

rent

stra

tegi

c pl

an d

evel

opm

ent e

fforts

Med

ium

Whi

le th

is pe

rform

ance

aud

it did

not

eva

luat

e th

e pr

ogre

ss n

or

cont

ent o

f the

cur

rent

dra

ft pl

ans,

we

enco

urag

e CF

PB’s

prog

ress

ive s

tage

s of

a s

trate

gic

plan

ning

pro

cess

to in

corp

orat

e G

PRA-

MA

conc

epts

out

linin

g hi

gh-le

vel o

rgan

izatio

nal p

riorit

ies,

“o

utco

me”

obj

ectiv

es, a

nnua

l per

form

ance

man

agem

ent p

lans

, re

latio

nshi

p to

fund

ing

and

budg

etar

y pl

ans,

pro

gres

s re

view

plan

s, a

ccou

ntab

ility

assig

nmen

ts, a

nd p

lans

for t

rans

pare

nt

mon

itorin

g an

d re

porti

ng.

Fund

Con

trol

Adm

inist

ratio

n

CF

PB d

emon

stra

ted

a re

peat

able

pro

cess

for p

repa

ring,

app

rovin

g an

d re

ques

ting

fund

ing

trans

fers

from

the

Fede

ral R

eser

ve

Th

ere

were

limite

d sp

ecific

writ

ten

polic

ies

and

proc

edur

es re

late

d to

the

proc

ess

for i

nitia

ting,

revie

wing

, and

app

rovin

g fu

ndin

g re

ques

ts

High

Co

ntin

ue to

bui

ld o

ut w

ritte

n po

licie

s an

d pr

oced

ures

for t

he

critic

al a

spec

ts o

f fun

ding

requ

est a

nd tr

ansf

er p

roce

ss.

Budg

et C

ontro

l/ Ex

ecut

ion

and

Re

porti

ng

Fu

nds

are

man

aged

with

a b

i-wee

kly b

udge

t to

actu

al re

port

from

BP

D –

Adm

inist

rativ

e Re

sour

ce C

ente

r’s fin

ancia

l man

agem

ent

syst

em

Th

e bu

dget

is lo

aded

at a

bur

eau-

wide

leve

l, mak

ing

indi

vidua

l bu

sines

s un

it acc

ount

abilit

y m

ore

diffic

ult t

o tra

ck

An

ICFR

con

tract

or is

wor

king

with

CFP

B on

initia

l risk

ass

essm

ent

and

will e

vent

ually

per

form

test

s of

ope

ratin

g ef

fect

ivene

ss o

f key

co

ntro

ls

Th

ere

were

limite

d sp

ecific

writ

ten

polic

ies

and

proc

edur

es re

late

d to

the

proc

ess

for b

udge

t aut

horiz

atio

ns a

nd a

lloca

tions

and

for

initia

ting,

revie

wing

, and

app

rovin

g ex

pend

iture

requ

ests

High

CFPB

sho

uld

cont

inue

to m

ake

prog

ress

with

its w

ork

unde

rway

to

mor

e-fu

lly d

ocum

ent p

olici

es re

late

d to

bud

get f

orm

ulat

ion

and

exec

utio

n / c

omm

itmen

t con

trol.

Supp

lem

enta

l doc

umen

tatio

n sh

ould

be

deve

lope

d de

finin

g de

taile

d fu

ndin

g an

d bu

dget

ary

proc

edur

es, r

oles

and

re

spon

sibilit

ies,

and

per

form

ance

man

agem

ent a

nd m

onito

ring

prac

tices

.

We

supp

ort t

he b

urea

u’s

plan

to b

egin

load

ing

the

budg

et a

t a

divis

iona

l leve

l in F

Y 20

12.


123

Table 31 presents list of considerations for CFPB compiled from our outreach with the Department of the Treasury – BPD – Administrative Resource Center as well as two comparable U.S. federal agencies with unique funding mechanisms and missions similar to that of CFPB (i.e., FDIC and OCC). These collective experiences, ideas, and recommendations are provided such that CFPB can further define and improve its budgeting process while it evolves as a bureau.

Table 31: Best Practices Considerations from Agency Outreach

Best Practices Considerations for CFPB as Organizational and Budget Processes Evolve

Multi-Year Budgeting:

In additional to the two-year budget formulation process (i.e., one year forward for the Operating Plan and two years forward for the President’s Budget), at least one agency recommended that CFPB implement a multiple-year investment planning process especially for significant capital expenditures that might have longer funding requirements.

Budget Formulation:

Two reference agencies strongly suggested that CFPB consider using a predominantly top-down approach to budget formulation. In the case of one agency which has used this method for at least 5 years and without any bottom-up budget calls, they discouraged the use of any extensive bottom-up approach.

While appreciative of the start-up operations for CFPB, a reference agency strongly encouraged the use of extensive budget expenditure research and comprehensive analysis prior to laying down an initial baseline budget each year. This agency found historical expenditures to be a strong predictor of future budgetary needs.

A reference agency recommended leveraging a centralized budget staffing model with a core team of budget analysts at headquarters along with at least one resource overseeing the agency’s performance management and review plans (e.g., GPRA-MA or a comparable program). Thereafter, each major departmental or division would have embedded budget analyst(s) – depending on size – which closely coordinated their work with that of the headquarters staff.

A reference agency recommended the use of budget “self-discipline” suggesting flattening or bringing the budget down in times of decreasing enforcement or oversight actions. This agency added this was especially relevant in their case where their funding was principally from risk-based insurance premiums levied on related entities.

Budget Execution and Performance Management

A reference agency recommended as a best practice extensive quarterly expenditure and performance measurement analysis reviewed against goals. This agency also performs a mid-year true-up of the budget, where necessary. Close monitoring of the budget execution results are made to make sure there is no “gaming” taking place.

This same agency has a relatively extensive performance-based pay program linked to “corporate” goals of the agency.

A reference agency suggested that, where possible, the formulated budget and agency performance measures (e.g., GPRA-MA or a comparable program) be approved at the same time to drive tighter alignment and integration.


124

Best Practices Considerations for CFPB as Organizational and Budget Processes Evolve

Budgeting and Performance Management Technology

A reference agency currently using spreadsheets for budget formulation recommended strong version control and historical archiving practices to avoid issues cropping up during the iterative cycles of formulation. Use of structured file naming conventions was a critical solution for this agency in lieu of a more sophisticated budget formulation solution.

This same agency commented that access to historic data was extremely helpful for accurate and effective budget formulation (in their case, they had access to an extensive financial and operational data warehouse for budget research and analysis). This agency found historical expenditures to be a strong predictor of future budgetary needs.

Another reference agency found the implementation of a budget formulation and execution software solution helpful to manage workflow needs and address version control requirements.


125

Appendix A: List of CFPB Officials who Provided Input

Operational Area CFPB Officials who Provided Input to this Audit

Human Capital and Organizational Development

Eben Darling, Team Lead, CHCO Operations Marilyn Dickman, Duputy Chief Human Capital Officer Dennis Slagter, Chief Human Capital Officer (CHCO) Mary Tamberrino, Team Lead, Workforce Planning & Strategic Initiatives, CHCO

Consumer Response

Sartaj Alag – Assistant Director, Consumer Response Darian Dorsey – Data/Analysis Lead Andrew Fay – Investigations Manager Cordelia Holmes – Manager, Intake Chris Johnson – Acting Section Chief, QA/Intake Steve Kirchgraber – Investigations Manager Christi Monk – Quality Analyst Scott Pluta – Attorney Advisor, Consumer Response Deb Reilly – Former Implementation Team Lead, Consumer Response Cathaleen Skinner – Attorney Advisor Julie Vanderslice – Investigations Manager LaShaun Warren – Product Development Manager

Information Technology

David Forrest – Chief Technology Officer Rachael Goldfarb – Acting Deputy CTO, Technology & Innovation Neeraj Gupta – Project Manager, Technology & Innovation Team Ori Lev – Deputy Assistant Director for Enforcement Litigation Joanna Pearl – Enforcement Attorney Nellisha Ramdass – Project Manager, Technology & Innovation Team Chris Willey – Chief Information Security Officer Mike Witt – Chief Information Security Officer

Communications and Transparency

Flavio Cumpiano – Congressional Liaison David DuBois – Deputy Director, Office of Servicemember Affairs Leandra English – Senior Advisor, External Affairs David Forrest – Chief Technology Officer Gail Hillebrand – Associate Director, Consumer Education and Engagement Jen Howard – Acting Assistant Director, Media Relations Peter Jackson – Acting Assistant Director, Office of Engagement Zixta Martinez – Assistant Director, Community Affairs Martin Michalosky – FOIA Manager Jeff Reilly – Executive Secretary Chris Willey – Chief Information Officer Mike Witt – Chief Information Security Officer

Budget

Ed Bustillo – Budget Analyst Judith Ochs – Program Analyst Victor Prince – Deputy Chief Operating Officer Jack Roziner – Audit and Internal Controls Manager Freddy Velez – Acting Chief Financial Officer Brian Winseck – Budget Analyst


127

Appendix B: List of Acronyms

AAR After Action Reviews

ACSI American Customer Satisfaction Index

AFR Americans for Financial Reform

ASR ASR Analytics, LLC

ATO Authority to Operate

B2B Business to Business

B2C Business to Consumer

BFEM Budget Formulation & Execution Manager

BPD Bureau of Public Debt

CAB Consumer Advisory Board

CFO Chief Financial Officer

CFPB Consumer Financial Protection Bureau

CHCO Chief Human Capital Officer

CIO Chief Information Officer

CIPSEA Confidential Information Protection and Statistical Efficiency Act

CIS Consumer Information System

CISO Chief Information Security Officer

COOP Continuity of Operations Plan

CR Consumer Response

CTO Chief Technology Officer

DOJ Department of Justice

ECQ Executive Core Qualification

EVM Earned Value Management

FASA Federal Acquisition Streamlining Act

FDIC Federal Deposit Insurance Corporation

FFATA Federal Funding and Accountability Transparency Act

FHFA Federal Housing Finance Agency

FIRREA Financial Institutions Reform Recovery and Enforcement Act

FISMA Federal Information Security Management Act

FITD Federal Information Technology Dashboard

FOIA Freedom of Information Act

GAGAS Generally Accepted Government Auditing Standards

GAO Government Accountability Office

GPRA Government Performance and Results Act

GPRA-MA Government Performance and Results Act Modernization Act

HCAAF Human Capital Assessment and Accountability Framework

HCMR Human Capital Management Report

HCPP Human Capital Program Plan

HR Human Resources


128

ICBA Independent Community Bankers of America

ICFR Internal Control over Financial Reporting

IRB Investment Review Board

IT Information Technology

ITIM Information Technology Investment Management

IVR Interactive Voice Response

LAN Local Area Network

MOU Memorandum of Understanding

NFC National Finance Center

OCC Office of the Comptroller of the Currency

OFE Office of Financial Education

OIP Office of Information Policy

OPM Office of Personnel Management

OSA Office of Servicemember Affairs

PII Personally Identifiable Information

PIR Post Implementation Review

PMO Program Management Office

POV Point of View

PRA Paperwork Reduction Act

SHCP Strategic Human Capital Plan

SORN System of Record Notices

WAN Wide Area Network


129

Appendix C: Audit Team

Dr. Peter Arena served as co-lead evaluator for Information Technology. Dr. Arena is a Founding Principal of ASR Analytics and has more than 15 years of experience in information technology, program evaluation, data management, and applied econometric modeling. He has held leadership positions with major global consultancies, and is a published expert in the fields of business intelligence and application development. For the past 10 years, Dr. Arena has led a broad range of analytic studies, involving large-scale data collection, database design and integration, application development, and relational database management. He has also led large-scale evaluations of operational performance for the Department of Commerce, the Department of the Interior, and the Department of Defense.

Edward Hau served as co-lead evaluator for Budget Formulation and Execution. Mr. Hau, a Director with RSM McGladrey, has more than 23 years of global consulting experience, focused on regulatory consulting, operations, and technology risk management. He has led or managed over 40 SOX / OMB A-123 and internal audit engagements in both the commercial and public sector with a focus on IT audit readiness, risk assessment, and controls evaluation. Mr. Hau also has deep expertise in the delivery of OMB A-123, Appendix A, business process reengineering, and Federal financial management transformation services, and has helped clients yield clean opinions related to Internal Controls over Financial Reporting (ICFR).

Michele Lebar served as lead evaluator for Human Capital and Organizational Development. Ms. Lebar has more than 20 years of experience in organizational development and change management consulting, including leadership/talent development/coaching, succession planning, and performance management. Ms. Lebar’s experience includes work with a variety of private sector industries, as well as extensive work with the Federal Government. Her recent work has included the design of a succession management training program for the Internal Revenue Service and the design of an organization development program for the Washington Metro Area Transit Authority. She holds a M.S. in Organizational Development from Johns Hopkins University.

Edward Merrill served as co-lead evaluator for Information Technology. Mr. Merrill, a Director with ASR Analytics, has more than 30 years of technical and program management experience in the federal government and commercial markets, specializing in IT strategic planning, ERP enhancement/integration, and infrastructure initiatives. He has managed business units and contracts in CMMI Level 3 and ISO 9000 environments, and has successfully managed multiple projects for software engineering, portal development, content management, ERP enhancement, and information assurance. Mr. Merrill has developed IT portfolio management and Software Development Life Cycle (SDLC) methodologies for large-scale program management offices, and has performed Independent Project Oversight (IPO) and IV&V engagements for both commercial and government organizations.

Sarah Sheehan served as co-lead evaluator for Budget Formulation and Execution. Ms. Sheehan, a Manager with RSM McGladrey, has more than 12 years of experience in public


130

sector financial consulting. Her recent work has involved leading “transition team” projects for the incoming President of Cook County, IL and the incoming Mayor of Chicago – with responsibility for streamlining budgeting and funding processes. Prior to joining McGladrey, Sarah served in the Governor’s office of the State of Illinois, where she managed the State’s American Recovery and Reinvestment Act program, with responsibility for $14 billion in ARRA money. Previously she worked in Deloitte Consulting’s public sector practice, where she specialized in budgeting, financial management and process redesign. Sarah has also worked at the City of Chicago’s Department of Public Health as the Assistant Commissioner of Finance, managing the department’s budget and more closely aligning its financial and contractual processes.

Michael Stavrianos served as Project Manager for this performance audit. Mr. Stavrianos, a Founding Principal of ASR Analytics, has nearly 20 years of professional experience in the fields of project management, program evaluation, and requirements management. Over the past 12 years, he has managed a broad range of analytic consulting engagements for the Internal Revenue Service (IRS), including 4 years leading the development of business rules and requirements for various Business Systems Modernization programs. He has also led recent, large scale evaluations of operational performance for both the IRS and the Department of Defense. In addition, he has designed and administered customer surveys for numerous Federal agencies, and he has served as a subject matter expert on several analytical projects for the IRS. He has been credentialed as a Project Management Professional (PMP) by the Project Management Institute.

Melissa Toledo served as lead evaluator for Consumer Response. Ms. Toledo is a Senior Director of Research and Strategy with RSM McGladrey, with more than 14 years of professional experience including strategic planning, business analysis, program management, systems implementations, and market research. Her expertise in business planning and strategy implementation has achieved profound impacts on corporate efficiency and productivity. Ms. Toledo built and manages a department that uses market intelligence to better serve clients, improve competitive differentiation and maximize growth. She was instrumental in the development of the firm’s first client loyalty measurement system and has also established several firm-wide performance initiatives that have resulted in significant improvements in client-experience ratings.

Tucker Warren served as lead evaluator for Communications and Transparency. Mr. Warren, a Managing Director with Hamilton Place Strategies, is a strategic communications professional with more than a decade of experience designing, implementing and managing small and large-scale campaigns for both the public and private sector. Most recently, he directed communications for the Financial Crisis Inquiry Commission – established by Congress to examine the causes of the financial and economic crisis. He served as the day-to-day spokesperson, developed the overall communications strategy, prepared commissioners for press conferences and hearings and handled the release of the Commission’s final report. Prior to this, Mr. Warren provided crisis communications counsel, conducted audits of internal and external communications programs, and evaluated long-term communications strategies for Edelman public relations. His clients included a top-tier multinational banking corporation, a multi-billion dollar government agency, and a prestigious Ivy League university.

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