The CFPB’s FY 2013-FY 2017 Strategic Plan, FY 2013 and FY 2014 Budget, and FY 2013 Annual Performance Plan and Report tracks the Bureau’s focus on supervision and enforcement. (While Director Cordray’s letter accompanying the report states that the CFPB has combined the three documents into a single report rather than publishing them as separate documents, the Strategic Plan was nevertheless also published as a separate document.)
The CFPB’s FY 2013 budget totals $541 million and the FY 2014 budget totals $497 million. (The report states that the decrease is due to one-time facilities investments in FY 2013.) Both budgets represent significant increases over the CFPB’s FY 2012 budget of $299 million.
The Strategic Plan lists four goals:
- Preventing financial harm to consumers while promoting good practices that benefit them.
- Empowering consumers to live better financial lives.
- Informing the public, policy makers, and the CFPB’s own policy-making with data-driven analysis of consumer finance markets and consumer behavior.
- Advancing the CFPB’s performance by maximizing resource productivity and enhancing output.
The report breaks down the total budget by goals, programs and spending categories. In FYs 2013 and 2014, more than 40% of the total budget is allocated to goal 1, which encompasses the CFPB’s rulemaking, enforcement and supervisory activities. The report also shows the number of full time employees (FTE) by program. For FY 2013, 563 of the total FTEs of 1,214 are assigned to Supervision, Enforcement, and Fair Lending, and for FY 2014, those numbers increase to 731 and 1,545, respectively. According to the report, “[m]ore than 40% of the growth in staff over the next two fiscal years will support Supervision, Enforcement, and Fair Lending activities, including the continued build out of a regional examination workforce.”
For each goal, the CFPB has set performance goals for it to use to assess its progress in meeting that goal. Highlights of those performance goals include:
- completion of regulatory proposals within 9 months of the close of the public comment period
- issuance of examination reports “within the CFPB’s established time periods” following the close of examinations
- ensuring that institutions receiving notice of matters requiring attention take corrective action by the prescribed timeframe
- where the CFPB has determined enforcement action is warranted, filing or settling actions within two years of opening an investigation
- successfully resolving cases filed in court and administrative proceedings whether by litigation, settlement, issuance of a default judgment or other means (This measure is intended to ensure that the CFPB “resolves as many actions as possible” while “pursuing complex and challenging actions when appropriate, even when success is not assured.”)
In February 2013, the Chamber of Commerce’s Center for Capital Markets Competitiveness sent a letter to Director Cordray suggesting several steps for the CFPB to take to improve the supervisory process. One of those steps was to create an end-point to eliminate open-ended exams. We hope the CFPB’s establishment of a performance goal requiring it to issue exam reports within its established time periods represents an attempt by the CFPB to be responsive to industry criticism.